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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #11-0039 ([LAN CARGO] [Mr. Carlos Ferriol])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: LAN CARGO

Individual Name: Mr. Carlos Ferriol

Location State: FL Country: US

View the Interpretation Document

Response text:

August 22, 2011




Mr. Carlos Ferriol

Dangerous Goods Coordinator


1901 NW 66 Ave

Miami, FL 33122

Ref. No.: 11-0039

Dear Mr. Ferriol:

This responds to your e-mail requesting clarification of the applicability of the emergency response telephone number requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to shippers who are not "registered" with an Emergency Response Information (ERI) provider. Specifically, you ask if a shipper is required to register with an ERI provider if a third party uses its contract number. Further, you ask if the shipper must provide a contract number.

Yes, another entity may use your emergency response telephone number by prior arrangement with the third-party ERI provider. The ERI provider may require evidence, such as your company name or registration number, indicating that your company contracted for the emergency response services. The shipper must ensure that the shipping papers that accompany the shipment include the information necessary to enable the ERI provider to identify the person by name, or contract number or other unique identifier. Provided that the ERI provider agrees, the shipper would not be required to provide its contract number on the shipping paper.

I hope this information is helpful. If we can be of further assistance, please contact us.


Ben Supko

Chief, Standards Development

Standards and Rulemaking Division


Regulation Sections

Section Subject
172.604 Emergency response telephone number