Interpretation Response #12-0119 ([Hazmat Service, Inc.] [Mr. Mark Phillip])

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

Interpretation Response Details

Response Publish Date: 07/31/2012

Company Name: Hazmat Service, Inc.

Individual Name: Mr. Mark Phillip

Location State: PA Country: US

View the Interpretation Document

Response text:

July 18, 2012

Mr. Mark Phillip

Hazmat Service, Inc.
1715 Millard St.
Bethlehem, PA 18017

Reference No. 12-0119

Dear Mr. Phillip:

This is in response to your email request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the emergency response telephone number requirement for shipping papers as adopted in the HM-206F final rule, "Revision of Requirements for Emergency Response Telephone Numbers," published on October 19, 2009 in the Federal Register [74 FR 53413] and effective on  October 1, 2010.  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 revision was published in the Federal Register [75 FR 53593] on September 1, 2010 under a final rule, "Hazardous Materials: Minor Editorial Corrections and Clarifications," HM-244C.  In your email, you state it is your understanding that an 800 number, international number, contract number (provided by the emergency response information (ERI) provider), or the name of the 24-hour emergency response registrant is required in the area of the shipping paper where the 800 number is placed.  You further state that the name of the 24-hour ERI provider is not needed or should not be placed in this area of the shipping paper.

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), to be noted in association with (immediately before, after, above or below) 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 on the shipping paper (such as the offeror) in this manner, there is no requirement to add the name twice by adding it in association with the emergency response telephone number.  In addition, please note that 

the emergency response telephone number is not required to be an 800 number.  Further, the international access code or the "+" (plus) sign, country code, and city code, as appropriate, must be included, as applicable. 

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

Sincerely,

T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division 

172.604(b)(1) & (b)(2)

Regulation Sections