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Interpretation Response #12-0068 ([Argonne National Laboratory] [Mr. Lee Stevens])

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

Interpretation Response Details

Response Publish Date:

Company Name: Argonne National Laboratory

Individual Name: Mr. Lee Stevens

Location State: IL Country: US

View the Interpretation Document

Response text:

May 10, 2012

 

 

Mr. Lee Stevens
Argonne National Laboratory
9700 South Cass Avenue
Argonne, IL 60565

Ref. No. 12-0068

Dear Mr. Stevens:

This responds to your February 28, 2012 email and your subsequent April 24, 2012 conversation and email with Lisa O"Donnell, a member of my staff, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the requirements of § 172.602(a)(1) and § 172.602(b)(3) are met by entering the Guide Number page of the Emergency Response Guidebook (ERG) on the shipping paper in association with the listing of the hazardous material and attaching the Guide Number page to the shipping paper.

The answer is no. Section 172.602(a)(1) states that the emergency response information must contain the basic description and technical name of the hazardous material as required by §§ 172.202 and 172.203(k). Section 172.602(b)(3) requires that the emergency response information is presented (i) on a shipping paper; (ii) in a document, other than a shipping paper, that includes both the basic description and technical name of the hazardous material; or (iii) related to the information on a shipping paper, in a separate document (e.g., an emergency response guidance document), in a manner that cross-references the description of the hazardous material on the shipping paper with the emergency response information contained in the document.

If a Guide Number page from the ERG is used, it must include the basic description and, if applicable, the technical name of the hazardous material. However, if the entire ERG is present on the transport vehicle, the requirements of § 172.602(a)(1) and § 172.602(b)(3) are satisfied and, though not prohibited, you are not required to entering the Guide Number page on the shipping paper in association with the listing of the hazardous material.

I hope this answers your inquiry. If you have further questions, please contact this office.

Sincerely,

 

Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division

172.602, 172.202

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.203 Additional description requirements
172.602 Emergency response information