DHL Global Forwarding — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Ave, SE Washington. D.C. 20590 Pipeline and Hazardous Materials Safety Administration DEC 6 2011 Dorothea A. Welk Dangerous Goods Compliance Specialist DHL Global Forwarding 1905 Raymond Ave. SW. Renton, WA 98057 Reference No.: 11-0230 Dear Ms. Welk: This is in response to your September 1, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the immediate availability of emergency response information. Specifically you ask if while a hazardous material is in a warehouse awaiting transport if emergency response information must be available in a hard copy or can it be electronically based and printed when needed. It is the opinion of this office that a printed hard copy of emergency response information must be present at a facility where a hazardous material is received, stored, or handled during transportation. Emergency response information is required by § 172.600(c)(1) to be immediately available for use at all times hazardous materials are present in the transportation stream. Facility operators where hazardous materials are stored are required by § 172.602( c )(2) to maintain the information required by § 172.602(a) whenever the hazardous material is present and must have the information available in a location that is immediately accessible to facility personnel in the event of an incident involving the hazardous material. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. Vl'IL!.· , Delmer Billings ~ Senior Regulatory Advisor Standards and Rulemaking Division#

Page 2·DHL Global Forwarding September I, 2011 Wthb ~ 112.. .~o~c.1J) Erne rje.n~ 1l-e~po~ , :r;,~/YlCl-h0P1 l \ -02.;30 U.S.DOT PHMSA Office of Hazmat Standards Attn: PHH-IO East Building 1200 New Jersey Avenue SE Washington, DC 20590-000 I Ref: 49 CFR Section 172.600 ( c) (1) GentlemenIMadam, This section requires that emergency response information about a hazardous material shipment must be immediately available at all times the hazardous material is present. My question concerns the words 44immediately available". When the hazardous material is in a forwarder or airline warehouse awaiting transport in what form does this information need to be immediately available? Must this be a hard copy or can it be contained in a computer to be printed when needed? Thank you. Sincerely, Dorothea A. Welk Dangerous Goods Compliance Specialist Direct Phone: 425-572-3064 DHL Global Forwarding 1905 Raymond AVE SW Phone: +1 1 425981 3500 Renton, WA 98057 www.dhl.com#