Polar Air Cargo — Hazardous Materials Safety Interpretation

Page 1. Departme Transportatic Washington, D.C. esearch anc MAY 4 2001 Mr. Paul J. Zinza Manager/Instructor Dangerous Goods Ref. No. 01-0035 Polar Air Cargo 100 Oceangate, 15th Floor Long Beach, CA 90802 Dear Mr. Zinza: This responds to your letter regarding the emergency response telephone number requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the ICAO Technica. Instructions for the Safe Transport of Dangerous Goods By Air. number may be in the form of a toll-free (e.g., Specifically, you ask whether the emergency response telephone "800") number. You state that U.S. from outside the United States. toll-free telephone numbers are inaccessible material for transportation must provide an emergency response As specified in § 172.604 (a), a person offering a hazardous telephone number for use in the event of an emergency involving the hazardous material. State Variation US12 in the ICAO Technical Instructions within, or transiting the U.S., emergency response information requires that for shipments to, from, including an emergency telephone number must be provided. area codes needed to complete the call from within the U.S. The would satisfy these requirements. use of a u.S. toll-free emergency response telephone number When dialed from outside the U.S., a U.S. toll-free telephone number may be accessed by contacting any U.S. operator. The procedures used to contact a U.S. operator may vary by country and calling charges may apply. be of further assistance. I trust this satisfies your inquiry. Please contact us if we can Sincerely, Hottie Z. Matthell Director, Office of Hazardous Materials Standards 112.1604 010035#

Page 2stevens POLAR AIR CARGO $172.604 January 30, 2001 Regomo otephone Mr. Edward T. Mazzulllo, Director Office of Hazardous Materials Standards Research & Special Projects Administration 01-0035 United States Department of Transportation Washington, DC 20590-0001 Dear Mr. Mazzullo: On page A3-1-15 of the ICAO Technical Instructions under notified state variation US 12, it clearly states: "The Transport Document required by these Instructions must include a 24-hour emergency response telephone number (including area codes and for international numbers for locations outside the U.S., the international access code and country and city codes needed to complete the call from within the U.S.) for use in the event of an incident involving the dangerous good(s). The number must be monitored at all times by a person who: 1) is knowledgeable of the hazards and characteristics of the dangerous good(s) being transported; 2) has comprehensive emergency response and accident mitigation information for the dangerous good(s); or 3) has immediate access to a person who possesses such knowledge and information. Simply stated, may the above text be interpreted to preclude shippers from providing a 24-hour emergency response telephone number solely in the form of an "800" number incident or emergency? This question has been raised time and time again by many wnich is thoroughiy inaccessibie outside the U.S. in the event of a dangerous goods prompt official written interpretation of this issue may be sent directly to me at the shippers, numerous carriers, and various dangerous goods training "schools." following address: Paul J. Zinza, Manager/Instructor Dangerous Goods Polar Air Cargo 100 Oceangate, 15"' Floor Long Beach, CA 90802 100 OCEANGATE, 15TH FLOOR → L.ONG BEACH, CA 90802 U.S.A. + TEL: (562) 436-7471 → FAx: (562) 436-9333 → SITA: LGBKUPO#

Page 3Thank you in advance for taking the time to clarify this important matter. Sincerely; Nails Jaza Paul J. Zinza Manager/Instructor Dangerous Goods#