Interpretation Response #25-0085
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Oak Harbor Freight Lines
Individual Name: Jeff McLaughlin
Location State: WA Country: US
View the Interpretation Document
Response text:
January 27, 2026
Mr. Jeff McLaughlin
Oak Harbor Freight Lines
35615 N Arlington Rd
Deer Park, WA 99006
Reference No. 25-0085
Dear Mr. McLaughlin:
This is in response to your June 24, 2025 letter and subsequent conversations with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for an emergency response phone number to be provided on a shipping paper. You ask whether the emergency response phone number may be placed on a shipping paper-other than immediately following the description of a hazardous material-provided the emergency response number remains readily identifiable and in conformance with § 172.604. In your incoming letter, you provide a picture of a shipping paper with the emergency response phone number highlighted in yellow.
Yes. Provided the emergency response phone number is readily identifiable and in conformance with the requirements specified in § 172.604(b), such a configuration would meet the requirements of § 172.604(a)(3)(ii). However, your picture also includes a separate, non-emergency phone number immediately following the description of the hazardous material, a location usually associated with an emergency response telephone number. While your emergency response phone number location in the above scenario is not in violation of the HMR, the non-emergency phone number immediately following the hazardous materials description on your shipping papers could lead to confusion and miscommunication in an emergency scenario. This Office recommends that you either relocate the non-emergency phone number or place the emergency response number immediately following the hazardous materials description as outlined in § 172.604(a)(3)(i) to prevent frustration of your shipments.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
§ 172.604, § 172.604(a)(3)(i), § 172.604(a)(3)(ii), § 172.604(b)
Regulation Sections
| Section | Subject |
|---|---|
| 172.604 | Emergency response telephone number |