{"operation":"document","citation":"17-0006","title":"Baker Hughes — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-04-28","effective_on":null,"summary":"17-0006 response to Baker Hughes concerning 172.604.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/170006.pdf","body":"<<<PAGE 1>>>\n\nGlobal Dangerous Goods Specialist\nBaker Hughes\n2001 Rankin Road\nHouston, TX 77073\nReference No. 17-0006\nDear Mr. Murphy:\nThis letter is in response to your January 19, 2017, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency\nresponse telephone numbers. Specifically, you ask whether the emergency response telephone\nnumber provided in 49 CFR § 172.604 may include an electronic welcome message that instructs\nusers to press #1 to be directly connected to a person with the emergency response information.\nThe answer is yes, provided the system does not create an undue delay. Section 172.604(a)\nrequires a person who offers a hazardous material for transportation to provide an emergency\nresponse telephone number of a person who either is knowledgeable of the hazardous material\nbeing shipped and has comprehensive emergency response and incident mitigation information\nfor that material, or has immediate access to a person who possesses such knowledge, and that\nthe number is monitored at all times the hazardous material is in transportation (including storage\nincidental to transportation). While the phrase \"immediate access\" is not defined in the HMR, it\nis intended to indicate that the emergency response information must be provided to a responder\nwithout undue delay. Therefore, the HMR permits using a phone system that includes a\nwelcome message and menu prior to directly connecting with the person knowledgeable about\nemergency response, provided such a system does not create an undue delay.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nFollow Up Flag:\nFollow up\nFlag Status:\nFlagged\nHi Shante/Alice,\nPlease submit this as a letter of interpretation. Mr. Murphy spoke with Edom.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Murphy, Joseph M [mailto:Joseph.Murphy2@bakerhughes.com]\nSent: Thursday, January 19, 2017 11:03 AM\nTo: INFOCNTR (PHMSA) < INFOCNTR. INFOCNTR@dot.gov>\nCc: Huynh, Monica <Monica.Huynh@bakerhughes.com>\nSubject: Letter of Interpretation Request - Emergency Response Telephone Number (49 CFR 172.604)\nImportance: High\nGood Day,\nI respectfully request a letter of interpretation addressing the regulations in 49 CFR 172.604 on the emergency response\ntelephone number.\nMy specific question is on how the phone number is answered. When the number is called, a welcome message quickly\ntells you the name of the company and asks you to press #1 for emergency response information, press #2 for ........\nUpon pressing #1, the phone is answered promptly by an employee who can provide the required emergency response\ninformation.\nIn 49 CFR 172.604 \"emergency response telephone number\" I do not see anything that prevents this process from being\nhandled in this manner. In fact when I spoke with and called other vendors we use, many had similar processes in place.\nWhat is addressed in 49 CFR 172.604(a)(2) speaks to an answering service that requires a call back such as a answering\nservice, answering machine, or beeper device - in this case NO call back is required. The only requirement is to press #1.\nPlease advise if the method our vendor is using meets the requirements of 49 CFR 172.604.\nVery Respectfully,\n1","truncated":false,"body_characters":3422}