Baker Hughes — Hazardous Materials Safety Interpretation

Page 1Global Dangerous Goods Specialist Baker Hughes 2001 Rankin Road Houston, TX 77073 Reference No. 17-0006 Dear Mr. Murphy: This letter is in response to your January 19, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency response telephone numbers. Specifically, you ask whether the emergency response telephone number provided in 49 CFR § 172.604 may include an electronic welcome message that instructs users to press #1 to be directly connected to a person with the emergency response information. The answer is yes, provided the system does not create an undue delay. Section 172.604(a) requires a person who offers a hazardous material for transportation to provide an emergency response telephone number of a person who either is 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 monitored at all times the hazardous material is in transportation (including storage incidental to transportation). While the phrase "immediate access" is not defined in the HMR, it is intended to indicate that the emergency response information must be provided to a responder without undue delay. Therefore, the HMR permits using a phone system that includes a welcome message and menu prior to directly connecting with the person knowledgeable about emergency response, provided such a system does not create an undue delay. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Follow Up Flag: Follow up Flag Status: Flagged Hi Shante/Alice, Please submit this as a letter of interpretation. Mr. Murphy spoke with Edom. Please let me know if you have any questions. Thanks, Jordan From: Murphy, Joseph M [mailto:Joseph.Murphy2@bakerhughes.com] Sent: Thursday, January 19, 2017 11:03 AM To: INFOCNTR (PHMSA) < INFOCNTR. INFOCNTR@dot.gov> Cc: Huynh, Monica <Monica.Huynh@bakerhughes.com> Subject: Letter of Interpretation Request - Emergency Response Telephone Number (49 CFR 172.604) Importance: High Good Day, I respectfully request a letter of interpretation addressing the regulations in 49 CFR 172.604 on the emergency response telephone number. My specific question is on how the phone number is answered. When the number is called, a welcome message quickly tells you the name of the company and asks you to press #1 for emergency response information, press #2 for ........ Upon pressing #1, the phone is answered promptly by an employee who can provide the required emergency response information. In 49 CFR 172.604 "emergency response telephone number" I do not see anything that prevents this process from being handled in this manner. In fact when I spoke with and called other vendors we use, many had similar processes in place. What is addressed in 49 CFR 172.604(a)(2) speaks to an answering service that requires a call back such as a answering service, answering machine, or beeper device - in this case NO call back is required. The only requirement is to press #1. Please advise if the method our vendor is using meets the requirements of 49 CFR 172.604. Very Respectfully, 1#