Oak Harbor Freight Lines — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration January 27, 2026 Mr. Jeff McLaughlin Oak Harbor Freight Lines 35615 N Arlington Rd Deer Park, WA 99006 Reference No. 25-0085 Dear Mr. McLaughlin: This is in response to your June 24, 2025 letter and subsequent conversations with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180) applicable to the requirements for an emergency response phone number to be provided on a shipping paper. You ask whether the emergency response phone number may be placed on a shipping paper—other than immediately following the description of a hazardous material— provided the emergency response number remains readily identifiable and in conformance with § 172.604. In your incoming letter, you provide a picture of a shipping paper with the emergency response phone number highlighted in yellow. Yes. Provided the emergency response phone number is readily identifiable and in conformance with the requirements specified in § 172.604(b), such a configuration would meet the requirements of § 172.604(a)(3)(ii). However, your picture also includes a separate, non-emergency phone number immediately following the description of the hazardous material, a location usually associated with an emergency response telephone number. While your emergency response phone number location in the above scenario is not in violation of the HMR, the non-emergency phone number immediately following the hazardous materials description on your shipping papers could lead to confusion and miscommunication in an emergency scenario. This Office recommends that you either relocate the non-emergency phone number or place the emergency response number immediately following the hazardous materials description as outlined in § 172.604(a)(3)(i) to prevent frustration of your shipments. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Alexander Wolcott Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Jacobson, N. 25-0085 From: INFOCNTR (PHMSA) To: Baker, Yul (PHMSA) Cc: Hazmat Interps Subject: FW: 172.604 interpretation request Date: Tuesday, June 24, 2025 13:37:43 Attachments: image001.png 3850_001_Redacted.pdf Hi Yul, Please see the below interpretation request and attachments. Let us know if you need anything, -Breanna From: Jeff McLaughlin <Jeff.McLaughlin@oakh.com> Sent: Tuesday, June 24, 2025 12:51 PM To: pipeline_interp_submittal <pipeline_interp_submittal@dot.gov>; INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: Jeff McLaughlin <Jeff.McLaughlin@oakh.com>; Tom Sanchez <tom.sanchez@oakh.com> Subject: FW: 172.604 interp request : This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Good morning, I was following up as we have not received a response or acknowledgment on the request below. Thank you, Jeff Jeff McLaughlin 35615 N Arlington Rd Deer Park, WA 99006 Jeff McLaughlin Pacific Northwest Safety Supervisor www.oakh.com | C: 406-899-3085#

Page 3From: Jeff McLaughlin <Jeff.McLaughlin@oakh.com> Sent: Tuesday, October 1, 2024 2:46 PM To: pipeline_interp_submittal@dot.gov Cc: Jeff McLaughlin <Jeff.McLaughlin@oakh.com>; Tom Mueller <Tom.Mueller@oakh.com>; Joe Guzman <Joe.Guzman@oakh.com> Subject: 172.604 interp request Good afternoon, We are requesting an interpretation of 172.604(a)(3) regarding how an emergency response phone number must be entered on a hazardous materials shipping paper: By utilizing ( option 1 ) outlined in 172.604(a)(3)(i) if the emergency response phone number is listed immediately following the description required by subpart C, do the requirements of 172.604(b) apply? Due to the word “or” following the criteria outlined in 172.604(a)(3)(i), and the addition of the language “entered once on a shipping paper in the manner prescribed in paragraph (b) of this section” under 172.604(a)(3)(ii) we feel that by utilizing ( option 1 ) we would not be required to meet the criteria outlined in 172.604(b) and our line manifest would be in compliance. Please see the attached HM BOL in question. Thank you for your time and consideration of this matter. Jeff Jeff McLaughlin Pacific Northwest Safety Supervisor www.oakh.com | C: 406-899-3085#

Page 4DSR189 9/17/24 Hazardous Hazardous Manifest: 076 23918 Lbs Weight 2090 1385 1525 Oak Harbor Freight Lines Trailer: V2953S UN3480, LITHIUM ION BATTERIES, UN3480, LITHIUM ION BATTERIES, CONSIGNEE CONTACT PHONE NUMBER EMERGENCY CONTACT* 800-424-9300 CALIFORNIA COMPLIANCE SURCHARGE Item description HAZARDOUS MATERIAL ------------- CLASS 9 916-452-3111 FUEL SURCHARGE CRATE CLASS 9 CRATE DEFICIT Dest: 025 Haz --- Package Pieces Freight Bill: 036-36169780 Freight Bill Date: 9/17/24 H/U N#

Page 5DSR189 9/17/24 Hazardous Hazardous Hazardous Hazardous 23918 Manifest: 076 Lbs Weight 3384 2869 106 50 Freight Lines Oak Harbor Trailer: V2953S **** SPECIAL DELIVERY REQUEST RQ, UN3266, CORROSIVE LIQUID, BASIC INORGANIC, NOS, (SODIUM HYDROXIDE POTASSIUM HYDROXIDE), 8, PGII RQ. UN3264, CORROSIVE LIQUID, ACID, PHOSPHORIC ACID), 8, PGII OXIDIZING, NOS, (SODIUM HYDROXIDE SODIUM CARBONATE PEROXYHYDRATE) UN2014, HYDROGEN PEROXIDE, AQUEOUS ACIDIC, INORGANIC, NOS, UN3084, CORROSIVE SOLIDS. APPOINTMENT DELIVERY CHARGES EMERGENCY CONTACT*1-800-255-3924 CALIFORNIA COMPLIANCE SURCHARGE Item description ____-----. DEL: BEFORE 16:00 /CALL FOR APPOINIMENT HAZARDOUS MATERIAL 8, (5.I), PG SOLUTION 5.1 Dest: 032 Haz Package ----- - - TB TB PT 9/17/24 Pieces ------ Freight Bi21: 031-37121079 BILL Date: H/U preight#