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Interpretation Response #11-0152 ([FedEx Express] [Mr. Thomas (TJ) Leech, III,])

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx Express

Individual Name: Mr. Thomas (TJ) Leech, III,

Location State: TN Country: US

View the Interpretation Document

Response text:

August 10, 2011




Mr. Thomas (TJ) Leech, III, CHMM

Manager, Dangerous Goods Hotline

FedEx Express

3690 Hacks Cross Road, Bldg. I, 3rd Floor

Memphis, TN 38125-8800

Ref. No. 11-0152

Dear Mr. Leech:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the emergency response telephone number requirements. Specifically, you ask whether the name of an Emergency Response Information (ERI) provider is required to be noted on shipping papers in accordance with § 172.604 of the HMR.

The answer is no. The HMR does not require the name of the ERI provider (such as ChemTel or Chemtrec) to be noted on a shipping paper. However, the telephone number of the ERI provider is required on the shipping paper (see § 172.604(a)).

A requirement specifying that the offeror who made an arrangement with the ERI provider must be identified on a shipping paper was adopted in a final rule under Docket Number PHMSA-2006-26322 (HM-206F), entitled "Hazardous Materials: Revision of Requirements for Emergency Response Telephone Numbers," and published in the Federal Register on October 19, 2009 [74 FR 53413]. A correction to that final rule's effective date was published in the Federal Register on October 22, 2010 [74 FR 54489], and an editorial correction was made under Docket Number PHMSA-2010-0195 (HM-244C) under a final rule entitled "Hazardous Materials: Minor Editorial Corrections and Clarifications," published in the Federal Register on September 1, 2010 [75 FR 53593].) The requirement is applicable to the registrant of the ERI provider; not the ERI provider. The HMR requires the name of the registrant of the ERI provider, (or contract number, or other unique identifier as provided by the ERI provider to identify the registrant), be noted in association with the ERI provider"s emergency response telephone number, only if the registrant is not already noted elsewhere on the shipping paper in a prominent manner. (See § 172.604(b)(1) and (b)(2)) Therefore, provided the registrant's name is already entered elsewhere in this manner, there is no requirement to add the name twice by adding it in association with the emergency response telephone number.

I hope this information is helpful. Please contact this office should you have additional questions.


T. Glenn Foster

Chief, Regulatory Review and Reinvention

Standards and Rulemaking Division


Regulation Sections

Section Subject
172.604 Emergency response telephone number