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Interpretation Response #20-0095

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

Interpretation Response Details

Response Publish Date:

Company Name: Council on the Safe Transportation of Hazardous Articles

Individual Name: Tom Ferguson

Location State: NY Country: US

View the Interpretation Document

Response text:

December 22, 2020

Tom Ferguson
Senior Technical Consultant
Council on the Safe Transportation of Hazardous Articles
10 Hunter Brook Lane
Queensbury, NY  12804

Reference No. 20-0095

Dear Mr. Ferguson:

This letter is in response to your October 2, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency response information. Specifically, you discuss usage of the Emergency Response Guidebook (ERG) mobile app by drivers of motor vehicles.

We have paraphrased and answered your questions as follows:

Q1. You ask whether display of emergency response information through the ERG mobile app on an electronic device (e.g., smartphone or tablet) meets the requirements of the HMR.

A1. The answer is no. The information used to meet the requirements of Part 172, Subpart G (172.600-172.606) must be in the form of a physical document printed legibly in English (see 172.602(b)). Electronic display of emergency response information, whether through the ERG app or other means, does not meet the HMR's requirements.

Q2. You ask whether PHMSA would consider revising the HMR to authorize electronic display of emergency response information as a way to meet emergency response requirements.

A2. The answer is yes. PHMSA continually revises the HMR to address developments in technology and transport methods that provide for an appropriate level of safety for the transportation of hazardous materials. You may ask PHMSA to add, amend, or delete a regulation by filing a petition for rulemaking in accordance with rulemaking procedures in 106.95-106.105.

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

172.600-172.606, 172.602(b), 106.95-106.105

Regulation Sections

Section Subject
106.100 Required information for a petition for rulemaking
106.105 PHMSA response to a petition for rulemaking
106.95 Requesting a change to the regulations
172.600 Applicability and general requirements
172.602 Emergency response information