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Interpretation Response #15-0108 ([W. J. Byrnes & Co] [Ms. Daisy Tate])

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

Interpretation Response Details

Response Publish Date:

Company Name: W. J. Byrnes & Co

Individual Name: Ms. Daisy Tate

Location State: AZ Country: US

View the Interpretation Document

Response text:

July 28, 2015

Ms. Daisy Tate
Export Manager
W.J. Byrnes & Co.
4455 S. Park Ave., Suite 113
Tucson, AZ 85714

Reference No. 15-0108

Dear Ms. Tate:

This is in response to your June 03, 2015 e-mail regarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency response telephone number requirements. Specifically you ask if a cell phone number provided by the offeror may be used to meet the emergency response telephone number requirements in § 172.604 provided the individual at the number provided has knowledge of the hazardous material being shipped and is available 24 hours a day seven days a week.

The answer to your question is yes. Section 172.604(a) requires a person that offers a hazardous material for transportation to provide an emergency response telephone number of a person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who possesses such knowledge, and that the number is a number that is monitored at all times the hazardous material is in transportation (including storage incidental to transportation). There is nothing in the HMR which would prohibit the emergency response telephone number from being the cell phone number of a person if that person is capable of providing the information required by § 172.604(a)(1) at all times the hazardous material is in transportation as required by § 172.604(a)(2).

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



Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.604, 172.604(a), 172.604(a)(1) 172.604(a)(2)

Regulation Sections

Section Subject
172.604 Emergency response telephone number