Hazmat Service, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE Washington. DC 20590 JUL 1 8 2012 Mr. Mark Phillip Hazmat Service, Inc. 1715 Millard St. Bethlehem, P A 180 I 7 Reference No. 12-0119 Dear Mr. Phillip: This is in response to your email request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the emergency response telephone number requirement for shipping papers as adopted in the HM-206F final rule, "Revision of Requirements for Emergency Response Telephone Numbers," published on October 19,2009 in the Federal Register [74 FR 53413] and effective on October 1, 2010. A correction to that final rule's effective date was published in the Federal Register on October 22, 2010 [74 FR 54489] and an editorial revision was published in the Federal Register [75 FR 53593] on September 1, 2010 under a final rule, "Hazardous Materials: Minor Editorial Corrections and Clarifications," HM-244C. In your email, you state it is your understanding that an 800 number, international number, contract number (provided by the emergency response information (ERI) provider), or the name of the 24-hour emergency response registrant is required in the area ofthe shipping paper where the 800 number is placed. You further state that the name ofthe 24-hour ERI provider is not needed or should not be placed in this area of the shipping paper. The HMR requires the name ofthe registrant ofthe ERI provider, (or contract number, or other unique identifier as provided by the ERI provider, to identify the registrant), to be noted in association with (immediately before, after, above or below) the ERI provider's emergency response telephone number, only if the registrant is not already noted elsewhere on the shipping paper in a prominent manner. (See§ 172.604(b)(l) and (b)(2)) Therefore, provided the registrant's name is already entered elsewhere on the shipping paper (such as the offeror) in this manner, there is no requirement to add the name twice by adding it in association with the emergency response telephone number. In addition, please note that#

Page 2the emergency response telephone number is not required to be an 800 number. Further, the international access code or the "+" (plus) sign, country code, and city code, as appropriate, must be included, as applicable. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: To: Subject: Thursday, May 17, 2012 10:54 AM Drakeford, Carolyn (PHMSA) FW: Request Letter of Interpretation Hi Carolyn, We received the following request for a letter of interpretation. Thanks, Victoria From: .Hazmat Service [mailto:info@hazmatservice.com] Sent: Wednesday, May 16, 2012 11:47 PM To: INFOCNTR (PHMSA) Subject: Request Letter of Interpretation Dear DOT Information Center, I am requesting a letter of interpretation regarding PHMSA Final Rule HM-206F. I have listed a few of the details below: I am CEO of a 24hr ER Service provider- Hazmat Service, Inc. At times there is some confusion regarding what is needed on the Dangerous Goods Declaration in the area where the 800# is placed. Some haz-mat carriers I transporters inform the shipper that along with the 800# they also need the name of the 24hr ER provider. The way I understand the ruling the following items are what is required: 800# or International# Contract# (provided by 24hr ER provider) or name of the 24hr ER Registrant. The name of the 24hr ER provider is not needed or should not be placed in this area. This information would not help emergency personal retrieve safety information for the inbound caller Thank You, Mark Phillip Hazmat Service, Inc. 1715 Millard St. Bethlehem, PA 18017 Tel: 888-932-9994 Fax: 866-596-1239 Email: info@hazmatservice.com 1#