Mr. Steve Laughlin — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OCT 1 4 2009 1200 New Jersey Ave. S.E. Washington, D.C. 20590 Mr. Steve Laughlin 5 19 Hillcrest Lane Lindenhurst, IL 60046 Ref. No.: 09-0215 Dear Mr. Laughlin: This responds to your letter dated September 24,2009 requesting clarification of the emergency response requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80). Specifically, you ask if a DOT identification number and proper shipping name listed on a Hazardous Waste manifest may be used to cross reference the Emergency Response Guidebook (ERG) to comply with the emergency response information requirements. The answer is yes. The shipping paper description for a hazardous material contains both a proper shipping name and an identification number. Either of these two communication elements, in conjunction with the "Name of Material" and "ID No." indexes contained in the ERG, may be used to cross-reference the description of the hazardous material on the hazardous waste manifest with the emergency response information contained in the ERG. Therefore, if there is a hazardous material description on the hazardous waste manifest and the ERG is present on the transport vehicle, the requirements of $ 172.602(b)(3)(iii) have been satisfied. I hope this answers your inquiry. Sincerely, arles E. Betts k, Standards Development Office of Hazardous Materials Standards#

Page 2Page 1 of 1 Drakeford, - - * Carolyn (PHMSA) -- -" <-*- - . * ---- From: INFOCNTR (PHMSA) Sent: Thursday, September 24, 2009 9:25 AM To: Drakeford, Carolyn (PHMSA) Subject: FW: Request for interpretation From: Steve Laughlin [mailto:sjlaughlin@comcast.net] Sent: Wednesday, September 23, 2009 3:45 PM To: INFOCNTR (PHMSA) Subject: Request for interpretation Mr. Mazzullo and staff, I would appreciate an interpretation on the following element of the hazardous materials regulations. 49CFR 1 72.602 addresses the form of the emergency response information required for a consignment of a hazardous material. My request deals with what methods are acceptable in meeting this requirement. All shipping papers of a hazardous materials consignment are required to display the proper shipping description which includes the UNINA Identification Number. Is this number displayed under the "Nature and Quantity of Goods" or in the case of a hazardous waste manifest, section 9b, a sufficient enough connection or reference to an Emergency Response Guide Number to satisfy the aforementioned standard? If the answer to this question is no, would referencing the actual Guide Number (ex. ERG 127) be enough to satisfy the requirement? Any background you can provide on this issue would obviously be appreciated. Thank you, Steve Laughlin Steve Laughlin, C t t M M / C€T 519 %LLcvest Lane Lindenhuvst, 224-381-3943 IL 6 0 0 4 6#