Argonne National Laboratory — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE Washington. DC 20590 MAY 0 9 2012 Mr. Lee Stevens Argonne National Laboratory 9700 South Cass A venue Argonne, IL 60565 Ref. No. 12-0068 Dear Mr. Stevens: This responds to your February 28, 2012 email and your subsequent April24, 2012 conversation and email with Lisa O'Donnell, a member of my staff, regarding the applicability ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the requirements of§ 172.602(a)(l) and§ 172.602(b)(3) are met by entering the Guide Number page of the Emergency Response Guidebook (ERG) on the shipping paper in association with the listing of the hazardous material and attaching the Guide Number page to the shipping paper. The answer is no. Section 172.602(a)(1) states that the emergency response information must contain the basic description and technical name of the hazardous material as required by§§ 172.202 and 172.203(k). Section 172.602(b)(3) requires that the emergency response information is presented (i) on a shipping paper; (ii) in a document, other than a shipping paper, that includes both the basic description and technical name of the hazardous material; or (iii) related to the information on a shipping paper, in a separate document (e.g., an emergency response guidance document), in a manner that cross- references the description of the hazardous material on the shipping paper with the emergency response information contained in the document. If a Guide Number page from the ERG is used, it must include the basic description and, if applicable, the technical name ofthe hazardous material. However, if the entire ERG is present on the transport vehicle, the requirements of§ 172.602(a)(l) and§ 172.602(b)(3) are satisfied and, though not prohibited, you are not required to entering the Guide Number page on the shipping paper in association with the listing of the hazardous material. I hope this answers your inquiry. If you have further questions, please contact this office. OJ; Ben Supko Acting Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: To: Subject: Thursday, March 01, 2012 5:59 PM Drakeford, Carolyn (PHMSA) FW: Hazmat Information Center Feedback: Emergency Response Information (Sections 172.1 – 172.807) Hi Carolyn, We received the following request for a letter of interpretation. Thanks, Victoria Victoria Lehman Hazmat Information Center (HMIC) http://phmsa.dot.gov/hazmat/info-center (202) 366-1035 -----Original Message----- From: PHMSA-Feedback Sent: Tuesday, February 28, 2012 12:43 PM To: PHMSA HM InfoCenter; PHMSA Webmaster Subject: Hazmat Information Center Feedback: Emergency Response Information (Sections 172.1 – 172.807) In looking at a previously submitted intepretation on 172.682(b) regarding the method of providing emergency response information (PHMSA Interpretation #09-0215) is the following scenario compliant with the requirements of 172.602? A reference (example: "ERG 137, attached") to the appropriate ERG number(s) for the hazardous materials being shipped is entered on the shipping paper (Hazardus Materials Bill Of Lading or Uniform Hazardous Waste Manifest, etc) in association with(after)the basic description for each applicable Proper Shipping Name (PSN) entered on the shipping paper. Attached to the shipping paper (which goes with the driver) are copies of the applicable Guide Number page(s) from the current Emergency Response Guide Book for the Guide Numbers listed on the shipping paper as being attached. As is customary, the Guide Number is located on the top of each page and would be the method by which the basic descriptions (including any technical names) for the material would be cross referenced with the Guide number(s) on the attachments. (In this scenario the page for ERG 137 would be attached to the shipping paper). Is this method a compliant way of providing the information required in 172.602 (a)(1) and (b)(3) since the appropriate basic description and any technical name(s) are all included in the shipping paper and can be cross referenced to the Guide number and vice versa? Thank you for your time and consideration. Name: Lee Stevens Organization: Argonne National Laboratory Email: stevensl@anl.gov Address: 9700 South Cass Avenue 1#

Page 3City: Argonne Zip Code: 60565 Phone: 630-252-2061 FAX: 630-252-9232 2#