{"operation":"document","citation":"06-0030","title":"TEN-E Packaging Services, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-02-22","effective_on":null,"summary":"06-0030 response to TEN-E Packaging Services, Inc. concerning 172.604, 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0030","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060030.pdf","body":"<<<PAGE 1>>>\n\nMr. Robert J. Ten Eyck\nRef. No. 06-0030\nDirector, Technical Services\nTEN-E Packaging Services, Inc.\n1666 County Road 74\nNewport, MN 55055\nDear Mr. Ten Eyck:\nThis is in response to your December 14, 2005 letter requesting clarification regarding the\nemergency response telephone number requirements for hazardous materials as specified\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your\nscenario, you are a third party test lab that performed a test on a packaging containing a\nhazardous material that was shipped to you by your client. Specifically, you ask if the\nHMR allow for you to ship the hazardous material back to your client using the client's\nemergency response telephone number.\nIn the scenario provided, you may use your client's emergency response telephone\nnumber by arrangement or agreement with the client. If the client uses a third party to\nprovide emergency response telephone service, the third party provider must recognize\nthat you are authorized to provide its telephone number on the shipping paper.\nI hope this information is helpful.\n\"Stile 4\nHo\nHattie L. Mitchell, Chief\nPie or ario and reia standards\n172.604(6)\n173.22\n060030\n\n<<<PAGE 2>>>\n\nSusan Gorsky\nU.S. DEPARTMENT OF TRANSPORTATION\nPipeline and Hazardous Materials Safety Administration\nOffice of Hazardous Materials Standards\nPHH-10\n400 7* Street S.W.\nWashington, DC 20590-0001\nRef. No.: 04-0274\nDear Susan:\nTEN-E Packaging Services, Inc. is an independent testing laboratory recognized by DOT as a third party\ntesting agency for conducting UN certification testing on non-bulk and IBC packaging. On occasion the\ncompany performs certain tests that require the client to send actual dangerous goods for the certification\nwork. For instance a client may contract with TEN-E to perform a DOT Appendix B compatibility test or a UN\ncertification test on a combination packaging with inner aerosol cans that make it impractical to certify the\npackaging without working with the actual product. As a part of its contract with the client, TEN-E returns the\nproduct to the client for re-work or disposal. TEN-E has always sought client approval to employ the same\nemergency response telephone number for the return shipment as that employed by the client for its initial\nshipment of dangerous goods to TEN-E.\nWith reference to a recent letter of clarification, Ref. No.:04-0274, TEN-E believes that its use of the client's\nemergency response telephone number would be recognized by the agency as being in compliance with Title\n49 CFR as outlined in Question and Answer #4 of the written interpretation. TEN-E would however appreciate\nhaving DOT comment on whether or not TEN-E's use of the client's emergency response telephone number\nmeets the requirements of Title 49 CFR.\nSincerely,\nRobert.i. Ten Eyck\n102\nDirector, Technical Services\nTEN-E Packaging Services, Inc.\nTEN-E Packaging Services, Inc.\n1666 County Road 74\n326 N Corona Avenue\nNewport, MN 55055\nOntario, CA 91764\nPhone: 651-459-0671\nPhone: 909-937-1260\nFax: 651-459-1430\nFax: 909-937-1260\nEmail: info@ten-e.com\nEmail: info@ten-e.com\nWeb: www.ten-e.com\nWeb: www.ten-e.com\nUNITED STATES - MN\nUNITED STATES - CA","truncated":false,"body_characters":3190}