Interpretation Response #25-0016
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Michael Colaner, LLC
Individual Name: Michael Colaner
Location State: NJ Country: US
View the Interpretation Document
Response text:
June 3, 2025
Michael Colaner
Consultant
Michael Colaner, LLC
Behalf of Quality Carriers, Inc.
10 Timber Wolf Drive
Hamilton, NJ 08620
Reference No. 25-0016
Dear Mr. Colaner:
This letter is in response to your February 9, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the display of the emergency response telephone number on shipping papers. You explain that Quality Carriers, Inc.—the company you represent—has a bill of lading (i.e., shipping paper) where the emergency response telephone number is displayed in a separate box. You note that the emergency response telephone number in a separate box that is not highlighted, the font is the same size as other information provided in the document, and the font color is not different from the rest of the text on the shipping paper. Is this method of placing the emergency contact telephone number in a separate box without highlighting, having the information in a larger font, or having the font in a different color satisfy § 172.604(a)(3)? Additionally, you reference a previously published letter of interpretation (Reference No. 16-0157) which states that "Section 172.604(a)(3)(ii) requires the emergency contact telephone number to be entered once on the shipping paper in a manner that sets it apart for quick and easy recognition." In this regard, is the response in Reference No. 16-0157 still valid?
Yes, using the method of placing the emergency contact telephone number in a separate box is consistent with § 172.604(a)(3) and Reference No. 16 0157 remains valid. According to § 172.604(a), a person who offers a hazardous material for transportation must provide a numeric emergency telephone number for use in an emergency involving hazardous materials. Section 172.604(a)(3)(ii) specifies how the emergency response telephone number must be displayed on a shipping paper. The number must be entered once on a shipping paper in a manner that is prominent, readily identifiable, in a clearly visible manner that allows the information to be easily and quickly found—such as highlighting, etc.—or in a manner that otherwise sets the information apart from other information provided on a shipping paper for quick and easy recognition. Based on the shipping paper you provided, the placement of the emergency response telephone number under the driver's signature is consistent with requirements in § 172.604(a)(3)(ii).
Please note that highlighting, using a larger font, or employing a different color from the surrounding text are considered alternative methods for making the emergency response telephone number "easily and quickly found" on a shipping paper but are not required methods for achieving the performance standard.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
§ 172.604(a), § 172.604(a)(3), § 172.604(a)(3)(ii)
Regulation Sections
| Section | Subject |
|---|---|
| 172.604 | Emergency response telephone number |