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Interpretation Response #17-0086

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

Interpretation Response Details

Response Publish Date: 11-14-2017
Company Name: CFI    Individual Name: Mr. Jeff Messer
Location state: MO    Country: US

View the Interpretation Document

Response text:
October 26, 2017
Jeff Messer
Safety Analyst
4701 East 32nd Street
Joplin, MO  64804
Reference No. 17-0086
Dear Mr. Messer:
This letter is in response to your August 14, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the Emergency Response Guidebook (ERG).  Specifically, you ask if a carrier is permitted to use an older version of the ERG (e.g., 2012 edition) provided it contains the same emergency response information as the current version.
If the emergency response information remains relevant and appropriate for the hazardous material, there is no prohibition against using an older version of the ERG.  According to § 172.602(b), emergency response information required for a hazardous material must be printed legibly in English, available for use away from the package containing the hazardous material, and presented on or with the shipping paper.  A separate document (e.g., ERG) that cross‑references the description of the hazardous material on the shipping paper with the emergency response information is one method of satisfying this requirement.
I hope this information is helpful.  Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

Regulation Sections

Section Subject
§ 172.602 Emergency response information