Rinchem Company, Inc. — Hazardous Materials Safety Interpretation

Page 1= of Transportation U.S. Department Washington, D C 400 Seventh Street, SW 20590 Research and Special Programs Administration NOV 2 7 2000 Mr. Robert L. Edgar Rinchem Company, Inc. Ref. No. 00-0307 Training Center 6149 Edith NE Albuquerque, NM 87107 Dear Mr. Edgar: This is in response to you letter of October 26, 2000, and subsequent phone conversations with Michael Johnsen, of my staff, regarding emergency response information required by § 172.602 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked if § 172.602(b)(3) requires that the 2000 Emergency Response Guidebook (ERG) "guide number" that applies to a hazardous material represented on the shipping paper be printed on the shipping paper. The answer is no. Neither the ERG "guide number" nor the page number needs to be printed on the shipping paper. If a carrier uses the ERG to fulfill the emergency response information requirements, the proper shipping name and UN ID number are acceptable to cross reference the correct entry in the ERG. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2Johnsen 8172.602 Rinchem Company, Inc. Emergency Training Center Shipping papers 6149 Edith NE Albuquerque, NM 87107 Phone: (505) 341-4173/74 00-0307 Fax: (505) 341-4168 E-mail: rintrain@rinchem.com October 26, 2000 Web page: www.rinchem.com Mr. Robert McGuire Acting Associate Administrator for Hazardous Materials Safety . US Department of Transportation Research and Special Programs Admin. 400 Seventeenth Street, S. W. Washington, DC 20590 RE: Interpretation of DOT Hazardous Materials Regulations Requested Dear Mr. McGuire: We are interested in your interpretation of the requirements for compliance with 49 CFR 172.602. When we ship hazardous material, we are required to prepare shipping papers as specified in 49 CFR subpart C (quantity, container types, number, proper shipping description(s), emergency response phone number, etc.). We insure the immediate response information is with the papers, as specified in 172.602(a), by carrying the most recently published DOT Emergency Response Guidebook (ERG). ' Does 172.602(b)(3) require that the ERG Guide number that applies to a hazardous material being transported must be written on the shipping paper (such as after each proper shipping description) in order to be in compliance? Do the cross references of the Proper Shipping Name and DOT ID Number on the papers and in the ERG satisfy the 172.602(b)(3)(iii) requirement, and, therefore, the ERG Guide - Number does not have to be listed? If MSDSs are used to supply the immediate response information specified in these regulations what additional information has to be listed on the shipping papers to Number? comply with 172.602 other than a cross reference such as the Proper Shipping Name or DOT ID Please call if you have any questions. I look forward to your reply so that we can ensure that all of our shipping papers are in complete compliance with DOT regulations. We Care, Robert L. Edear E, S&H Manager#