Kajuligan Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington. DC 20590 1200 New Jersey Avenue SE Pipeline and Hazardous Administration Materials Safety FEB 2 5 2015 Mr. Cliff Croft Kajuligan Inc. 1533 Kirkwood Drive Geneva, IL 60134 Reference No. 14-0245 Dear Mr. Croft: This is in response to your December 22, 2014 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the emergency response telephone number requirements of HMR § 172.604(a). You ask for confirmation of your understanding that if the emergency response telephone number is located in the United States, it does not have to include the "t" (plus) sign, country code and city code, as appropriate, even if the shipment is intended to be transported internationally by air. Your understanding is correct. In accordance with § 172.604(a) an emergency response telephone number located within the United States only requires the telephone number and area code. The "t" (plus) sign, country code and city code, as appropriate, must only be included if the telephone number is outside the United States. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Babich 5177.604(a) Dodd, Alice (PHMSA) meroncy hesponse 14-0245 From: Sent: Ciccarone, Michael CTR (PHMSA) To: Monday, December 22, 2014 3:49 PM Subject: Hazmat Interps FW: Request for formal interpretation for 49CFR 172.604(a) Shante/Alice, Please submit this for a formal letter of interpretation. Mr. Croft spoke with Jordan in the HMIC. Thanks, Mike From: Cliff Croft [mailto: cliff.e.croft@gmail.com] To: Ciccarone, Michael CTR (PHMSA) Sent: Monday, December 22, 2014 3:37 PM Subject: Re: Request for formal interpretation for 49CFR 172.604(a) The Company address is Kajuligan Inc. 1533 Kirkwood Dr Geneva, IL 60134 On Mon, Dec 22, 2014 at 2:30 PM, <m.ciccarone.ctr@dot.gov> wrote: Dear Cliff, hazardous materials regulations (49 CFR Parts 171-180). We have received your request for a written letter of interpretation regarding the Please include your company's physical address to expedite the submission process. Sincerely, Mike, Hazardous Materials Specialist An e-mail response from this office is considered informal guidance. be requested in accordance with 49 CFR 105.20. http://phmsa.dot.gov/hazmat/regs/interps Formal guidance may#

Page 3From: Cliff Croft [mailto: cliff.e.croft@gmail.com] To: PHMSA HM InfoCenter Sent: Monday, December 22, 2014 2:33 PM Subject: Request for formal interpretation for 49CFR 172.604(a) I would like to get a formal written interpretation for 172.604(a) with regard to the international access code. If we are making an International shipment utilizing an emergency phone number located in the united states are we required to include the international access code or "+" sign and country code? The way the rule is written it appears to be based on where the telephone number is located and not where the shipment originates or its destination. So it is my understanding if a company is using Chemtrec 703-245-2380 on an air declaration for an international shipment the "+" and country code is not required since the phone number originates within the United States. Thank you, Cliff Croft Kajuligan Inc. 2#