NACA Logistics — Hazardous Materials Safety Interpretation

Page 1J.S. Department f Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazarcious Materials Safety MAR 30 2006 Mr. Eric Fischer Reference No. 06-0056 NACA Logistics 1477 Hamilton Parkway Itasca, IL 60143 Dear Mr. Fischer: This is in response to your February 27, 2006 letter asking us to confirm the accuracy of an answer we provided in a February 21, 2001 letter to Garry Howell of the Overnite Transportation Company concerning whether or not a shipper may enter more than one emergency response telephone number on a shipping paper for a hazardous materials shipment under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your example, you state you receive some bills of lading with two emergency response telephone PM" and the other is available all other times. numbers accompanied by wording stating one number is available from "8:00 AM to 5:00 The answer is yes. More than one emergency response telephone number may be entered on a shipping paper and the numbers may be active for different times provided that together they satisfy the requirements prescribed in § 172.604(a) that an emergency response telephone number be monitored at all times the hazardous material is in transportation, including storage incidental to transportation. The person monitoring the number must be knowledgeable of the characteristics of the hazardous material and have comprehensive emergency response information about the material, or immediate access to a person who possesses such knowledge and information. See § 172.604(a)(1) and (a)(2). Although the HMR do not currently state the shipper is required to provide the time period for which an emergency response telephone with a limited time is available, it is the opinion of this Office that the shipper should clearly state the time period the number is available and to which number the restricted time applies I hope this information is helpful. Sincerely, To the a made Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards HIMA HII 172:604(a) 060056#

Page 2Nickels, Matthew <PHMSA> Edmonsor Sent: From: eric.fischer@vanguardlogistics.com Subject: To: INFOCNTR < PHMSA> Monday, February 27, 2006 9:09 AM Information Center Comments/Questions is the result of your feedback form. (eric.fischer@vanguardlogistics.com) It was submitted by 09:08:41. on Monday, February 27, 2006 at Email: eric.fischer@vanguardlogistics.com Name: Eric Fischer Category: Emergency Response Information (Sections 172.1 - 172.807) Organization: NACA Logistics Street: 1477 Hamilton Parkway City: Itasca State: Illinois Zip Code: 60143 Phone: 847-238-5024 Fax: 847-238-5284 I would like to receive an interpretation of 172.604 concerning the use of multiple Comments: Dear Sirs, emergency response telephone numbers on a shipping paper. A related interpretation was issued by Johr Gale to the Overnite Transportation Co on Feb 21, 2001 with reference when required, any hazmat shipment we carry would need an emergency response phone number and state an an he then oft another sumer 10 over the time star Dr the one za to cover the 24 hour period. together, they are. work day period. So each number individually is not valid 24 hours a day but if used I do not believe this practice meets the requirements of 172.604. Am I correct? Thank ric Fischer vou for your time and help. NACA. Logistics Hazardous Materia…s Manager#

Page 3U.S.Department Research and of Transportation Washington. D.C Special Programs Administration FEB 2 1 2001 Mr. Garry Howell Overnite Transportation Company Environmental Supervisor Ref. No. 01-0018 Gaffney, SC P.O. Box 246 29341-0246 Dear: Mr. Howell: concerning hazardous material shipping paper requirements under in response to your letter dated January 10, 2001, the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). questions are paraphrased and answered as follows: May a "#" sign be used as a unit of measure to indicate weight on a shipping paper (i.e., pounds)? Yes. "#" sign as Section 172.202 (a) (5) does not prohibit the use of a unit of measurement. 02. May a shipping paper contain more than one emergency response telephone number? A2. telephone number is entered on a shipping paper, each must However, when more than one emergency response addition, an emergency response telephone number that is neet the requirements under $ 172.604 (a) and (b). Ir specific to a particular shipping description must be clearly identified as such. I hope this satisfies your request. Sincerely, Office of Hazardous Materials Standards 010018#