Chemical Accident Reconstruction & Services, Inc — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washingion, S.C. 20590 Special Programs Research and JUL 29 2004 Administration Michael Fox, Ph. D. Ref. No. 04-0149 Founder Chemical Accident Reconstruction 9121 East Tanque Verde Road Services, Inc. Tucson, AZ 85749 Dear Dr. Fox: This is in response to your May 24, 2004 letter concerning emergency response information requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and addressed as follows: Q1: Must the emergency response information required under § 172.602 include information regarding non-hazardous material that is loaded on the vehicle with the hazardous material? A1: No. Section 172.602 does not require emergency response on a transport vehicle with hazardous materials. Emergency informaticn regarding non-hazardous materials that is loaded response information must be provided only for the applicable hazardous materials as specified in § 172.600. Q2: Do the HMR contain any requirements for emergency responders information specified in § 107.602? on how to handle an incident based on the emergency response A2: No. Although the HMR specify the emergency response the HMR do not specify guidelines on how nformation that must be provided to emergency responders he emeraenc responders must use that information. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Office of Hazardous Materials Standards Standards Development 172.602 040149#

Page 2Chemical Accident Reconstruction Services, Inc. May 24, 2004 Via Priority Mail BAH U.S. Department of Transportation Office of Hazardous Materials Standards $172.602 ATTN: Director Washington, D.C 20590 Emergency Response Re: Emergency Response Information 04-0149 Dear Director: The Emergency Response Information required by 49 CFR 172.602 is defined as: "information that can be used in the mitigation of an incident involving hazardous materials." This includes the "immediate methods for handling fires." My question has to do with the number and variety of hazardous materials on board a specific trailer. For example, what if a semi-trailer was transporting 12,000 pounds of non-hazardous combustible materials, together with ten different hazardous materials totaling no more than 1000 pounds. Should the "immediate methods for handling a fire" consider the entire load, or just the individual hazardous materials? For example, if there were only 3 ounces of a Water should fire fighters let the entire trailer burn to the ground (releasing over 13,000 pounds Reactive material on board, and water was the only extinguishing medium available, of potentially toxic combustion products) or extinguish the fire with water? Is the responding fire department expected to flip through the ERG for the 10 different hazardous materials and then make an on-the-spot decision about the best method to mitigate a fire, or are the shippers and transporters supposed to evaluate the entire load and prepare the mitigation strategy before the trailer leaves the dock, thereby making it Sincerely, MIcHAEL FoX Michael Fox, Ph.D. Founder 9121 E. Tanque Verde Road #105, Tueson, Arizona 85749 800-MIKE-FOX (645-3369) Fax: 520-749-0861#