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Interpretation Response #17-0006 ([Baker Hughes] [Mr. Joseph Murphy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Baker Hughes

Individual Name: Mr. Joseph Murphy

Location State: TX Country: US

View the Interpretation Document

Response text:

April 28, 2017

Joseph Murphy
Global Dangerous Goods Specialist
Baker Hughes
2001 Rankin Road
Houston, TX 77073

Reference No. 17-0006

Dear Mr. Murphy:

This letter is in response to your January 19, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency response telephone numbers. Specifically, you ask whether the emergency response telephone number provided in 49 CFR § 172.604 may include an electronic welcome message that instructs users to press #1 to be directly connected to a person with the emergency response information.

The answer is yes, provided the system does not create an undue delay. Section 172.604(a) requires a person who offers a hazardous material for transportation to provide an emergency response telephone number of a person who either is 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 monitored at all times the hazardous material is in transportation (including storage incidental to transportation). While the phrase "immediate access" is not defined in the HMR, it is intended to indicate that the emergency response information must be provided to a responder without undue delay. Therefore, the HMR permits using a phone system that includes a welcome message and menu prior to directly connecting with the person knowledgeable about emergency response, provided such a system does not create an undue delay.

I hope 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

172.604, 172.604(a)

Regulation Sections