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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 #12-0259 ([Dangerous Goods Advisory Council] [Mr. Vaughn Arthur])

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

Interpretation Response Details

Response Publish Date:

Company Name: Dangerous Goods Advisory Council

Individual Name: Mr. Vaughn Arthur

Location State: DC Country: US

View the Interpretation Document

Response text:

December 18, 2012

Mr. Vaughn Arthur
Dangerous Goods Advisory Council
1100 H Street, NW, Suite 740
Washington, DC 20005

Ref. No. 12-0259

Dear Mr. Arthur:

This responds to your November 8, 2012 letter requesting PHMSA to reconsider the opinion issued in our May 9, 2012 letter (Ref. No. 12-0068).  PHMSA has issued several letters of interpretation, including our May 9, 2012 letter (Ref. No. 12-0068), responding to requests for us to clarify the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the emergency response information required in § 172.602(a)(1) and § 172.602(b)(3). 

In those letters PHMSA has consistently held that the requirements of § 172.602(a)(1) and § 172.602(b)(3) are not met solely by entering the Guide page of the Emergency Response Guidebook (ERG) on the shipping paper in association with the listing of the hazardous material and attaching the Guide page to the shipping paper.  PHMSA has stated that when an ERG Guide page, and not the entire ERG is used, the Guide page must include the basic description and if applicable, the technical name of the hazardous material.  PHMSA has further stated that if the entire ERG, not just an ERG Guide page, is present on the transport vehicle, the requirements of § 172.602(a)(1) and § 172.602(b)(3) are satisfied.

The emergency response information requirements are designed to facilitate the immediate and reliable communication of information concerning the nature and quantity of hazardous materials moved in transportation, so that carrier personnel, law enforcement officials, and first responders know to take appropriate precautions in handling, law enforcement, and emergency response situations. Ultimately, the emergency response information is only as effective as the ability of these individuals to quickly identify the hazardous materials present on the vehicle and respond appropriately to an incident involving those materials. Accordingly, if the emergency response information is provided in an ERG Guide page attached to the shipping paper, we require that the Guide page include the basic description and if applicable, the technical name of the hazardous material.

If you believe a rulemaking change is warranted, we invite you to file a petition for rulemaking in accordance with § 106.95 including all information (see § 106.100) needed to support your petition.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
106.100 Required information for a petition for rulemaking
106.95 Requesting a change to the regulations
172.602 Emergency response information