American Dental Supply, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh St., S.W. Research and Administration special Programs JAN 1 9 2001 Mr. Les Hochhauser Reference No.: 00-0368 American Dental Supply, Inc. 2600 William Penn Highway Easton, PA 18045 Dear Mr. Hochhauser: This is in response to your December 15, 2000 letter regarding the emergency response telephone number requirements under the Hazardous Materials Regulations (49 CFR Parts 171-180). You asked whether a countrywide pager number meets the requirements for the emergency response telephone number. The answer is no. As required by § 172.604, the emergency response telephone number must be onitored at all times the hazardous material is in transportation by a person who is eith howledgeable of the characteristics of the hazardous material and has comprehensiv emergency response information, or has immediate access to a person who possesses such knowledge. Services that require a "call back" (e.g., answering service, answering machine or pagers) are not acceptable and are not in compliance with the requirements in § 172.604. I hope this satisfies your request. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 000368 172,604#

Page 2Corbin §172.604 Emergency Response AMERICAN DENTAL SUPPLY, INC. Telephone 2600 WILLIAM PENN HIGHWAY' Number EASTON, PA. 18045 610 252 1464 FAX 610 252 2822 00-0368 Dec. 15, 2000 J.S. Dept of Transportation RSP/ office of Hazardous Materials Standards (DHM-10 400 7th St. South West Washington D.C. 20590-0001 Dear Edward T. Mazzullo, Director We need your assistance with the hazardous materials regulations. We sell a variety of chemical and ceramic materials to the dental laboratory in small bottles. Most of the materials are non-hazardous but a few do meet the Packing Group II definition. In the interest in providing right-to-know data for our customers, we provide Safety Data Sheets on the materials. The sheets bear our company name and address. We also provide an emergency telephone number, in the following fashion. During normal business hours, the phone number given will contact a knowledgeable person in our office. After hours, weekends and holidays a number is given that pages (countrywide) a degreed chemist who is knowledgeable about all the products. Due to our size as a company and the number of products, this approach is satisfactory to our customers and we feel provides the necessary protection and emergency contact. DOT regulations in the most cost-effective manner for us. In the 25 plus overs this in your files. Obviously, we want to be in compliance with years we have been shipping merchandise, we have never had a spill of emergency response personnel. Can you help us with this? Please feel hazardous materials that resulted in a phone call from a carrier or Hochhauser#