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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 #13-0106 ([Kriska Transportation] [Mr. Bob Duncan])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kriska Transportation

Individual Name: Mr. Bob Duncan

Country: CA

View the Interpretation Document

Response text:

July 31, 2013

 

Mr. Bob Duncan
Driver training Coordinator
Kriska Transportation
300 Churchill Road
K0E 1T0 Prescott, Ontario
Canada

Ref. No. 13-0106

Dear Mr. Duncan:

This responds to your letter dated May 15, 2013, requesting clarification concerning the responsibility for providing emergency response information, as specified in § 172.602 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  In your letter, you state that you are a Canadian motor carrier and ask who is ultimately responsible for ensuring that emergency response information is present on the transport vehicle.  Additionally, you ask if the basic description of the hazardous material, including the technical name, is required on a separate guide page or if a “North American Emergency Response Guide (NAERG) Page No.” indication on the shipping paper would satisfy the emergency response information requirements.

A shipper or an agent performing functions of a shipper is responsible for ensuring that an emergency response information document is provided to the carrier.  Each carrier is responsible for maintaining the emergency response information document, as required.  A carrier may elect to place a document, such as the 2012 NAERG, in its transport vehicle to satisfy the emergency response information requirements.

In addition, if a separate document, such as a guide page from the 2012 NAERG is used, it must include the basic description of the hazardous material and, if applicable, the technical name, such as when generic or n.o.s. descriptions are used.  A "Guide Page No.” is not required on a shipping paper, and, although not prohibited, would not singularly satisfy the emergency response information requirements prescribed in § 172.602.

I trust this information is helpful.  Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.602

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
172.602 Emergency response information