W. J. Byrnes & Co — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington. DC 20590 1200 New Jersey Avenue SE Pipeline and Hazardous Materials Safety Administration JUL 2 8 2015 Ms. Daisy Tate Export Manager W.J. Byrnes & Co. 4455 S. Park Ave., Suite 113 Tucson, AZ 85714 Reference No. 15-0108 Dear Ms. Tate: This is in response to your June 03, 2015 e-mail regarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency response telephone number requirements. Specifically you ask if a cell phone number provided by the offeror may be used to meet the emergency response telephone number requirements in § 172.604 provided the individual at the number provided has knowledge of the hazardous material being shipped and is available 24 hours a day seven days a week. The answer to your question is yes. Section 172.604(a) requires a person that offers a hazardous material for transportation to provide an emergency response telephone number of a person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who possesses such knowledge, and that the number is a number that is monitored at all times the hazardous material is in transportation (including storage incidental to transportation). There is nothing in the HMR which would prohibit the emergency response telephone number from being the cell phone number of a person if that person is capable of providing the information required by § 172.604(a)(1) at all times the hazardous material is in transportation as required by § 172.604(a)(2). I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Duan APpl Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Webb 9172.604 Dodd, Alice (PHMSA) Emergencykespons From: 15-0108 Sent: Geller, Shelby CTR (PHMSA) To: Wednesday, June 03, 2015 4:39 PM Subject: Hazmat Interps FW: Request for formal letter of interpretation Dear Shante and Alice, Attached is request for a formal letter of interpretation. Ms Tate spoke with Jordan Rivera in the HMIC. Thanks, Shelby From: Daisy Tate [mailto:daisy.tate@byrnesglobal.com] Sent: Wednesday, June 03, 2015 12:43 PM To: INFOCNTR (PHMSA) Subject: Request for formal letter of interpretation The below question was submitted and I was advised to send this a formal request for a letter of interpretation. Please advise on the below question, thank you Regards; Dairy Tate Export Manager W.J. Byrnes & Co. Phone: 520-889-2275 Fax: 520-294-0330 From: Daisy Tate [mailto:daisy.tate@byrnesglobal.com] To: infocntr@dot.gov Sent: Tuesday, June 02, 2015 1:38 PM Subject: Question regarding the Emergency Contact Telephone number on the Bill of Lading Please advise if the shipper's representative's cell phone number is acceptable as the Emergency Contact Telephone number, when this individual has knowledge of the hazardous material and is available 24/7 on this number. Regards, Daisy Tate Export Manager W.J. Byrnes & Co. 4455 S. Park Avenue, Suite 113, Tucson, Arizona 85714 Phone: 520-889-2275 Fax: 520-294-0330 tus@byrnesglobal.com www.byrnesglobal.com your global partner for personaliced logistics services sinie 1907 1#