# NACA Logistics — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 06-0056
- **title:** NACA Logistics — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2006-03-30
- **effective on:** Not available
- **summary:** 06-0056 response to NACA Logistics concerning 172.604.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0056.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0056
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060056.pdf
**body:**

<<<PAGE 1>>>

J.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 2>>>

Nickels, 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 3>>>

U.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
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