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Re: DOT Emergency Response Phone Number



With all due respect, it is a silly requirement.  A far more practical solution would be a comprehensive response manual in the hands of all responding agencies.  This is a good example of ill conceived regulation in the post-environmental hysteria era.
 
One is forced to ponder what kept the world from ending prior to 1970... 
----- Original Message -----
From: Bruce Bugg
Sent: Monday, June 09, 2003 1:11 PM
Subject: RE: DOT Emergency Response Phone Number

Having been there when the ERI requirement came out in the early 90's, and having dealt with various Emergency Response situations involving using the Emergency Contact numbers, I can offer the following comments:
 
The DOT intent is for the number to be either the actual shipper or receiver of the product, who also has the resources available to advise a responder, or a number akin to CHEMTREC. CHEMTREC requires that companies using its service register with them, provide MSDS for the products, and then telephone numbers of competent company employees who have knowledge of the product. In large chemical companies with many branches, that's usually someone at he manufacturing plant. There are other companies in the business besides CHEMTREC, but I use them as the example because they are the Granddaddy of the concept.
 
I've used these services in several incidents, none involving radioactive materials. In every case that I used them, they were able to find somebody to wake up at odd hours to share my misery. They do this by having their operator bridge the responder telephonically with the company person. The delay in contacting the company person was never more that 5 - 7 minutes. The first thing I learned about these operations is to immediately get the name and direct phone number of the person I was talking to, because on two occasions the telephone bridge failed in the middle of a conversation.
 
The only radioactive materials incidents I worked have both involved radio pharmaceuticals, both from the same source (the folks outside Boston, Massachusetts), with their own, internal response system. In neither case did I talk to them directly, so I can't comment on what happened there. In neither case did the materials leave the inner packaging.
 
It may be unfair, but I think that a lot of how these cases will be dealt with depends on how much notice the incident gets in the media, whether the emergency contact system fails the responders' needs, and whether that failure gets communicated to US DOT. It also will depend to a certain extent on the material involved. If it's gasoline, diesel fuel, or even propane, the responders are less likely to call for help with HOW to respond. Their call will be to find out who the clean-up contractor is and how soon will they be there...
 
It's US DOT's regulation and therefore enforcement depends largely on DOT's interpretation, not NRC's.

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Capt. Bruce Bugg
Special Projects Coordinator
Law Enforcement Division
Georgia Department of Motor Vehicle Safety
P.O. Box 80447
Conyers, GA  30013-8047
voice:  678.413.8825
fax:    678.413.8832
e-mail: obbugg@dmvs.ga.gov

 
 
 
-----Original Message-----
From: William V Lipton [mailto:liptonw@DTEENERGY.COM]
Sent: Monday, June 09, 2003 10:27
To: radsafe@list.vanderbilt.edu
Subject: DOT Emergency Response Phone Number

I am trying to resolve conflicting interpretations of the requirement of 49 CFR 172.604(a)(2) that the emergency response telephone number required on DOT shipping papers be:  "The 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 information..." [emphasis mine].

In Information Notice 92-62, "Emergency Response Information Requirements for Radioactive Material Shipments," the NRC states that, "...Emergency responders will expect this [emergency response] information to be provided within 15 minutes..."

However a DOT/RSPA letter of interpretation (letter to Mr. Andrew C. Rymer, dated April 5, 2001, Ref. No. 00-280 - available thru link on DOT/RSPA hazmat safety web site) states:  "We are aware of the Nuclear Regulatory Commission's (NRC) Information Notice 92-62 that was issued... The NRC provided its opinions that emergency responders would want or expect that this information be provided within 15 minutes.  It is our opinion that an emergency responder would want the information as quickly as possible and that, in many if not most hazardous materials transportation situations, a delay of 15 minutes would be unacceptable."  [emphasis mine].

If not 15 minutes, is there a workable time limit?  The letter of interpretation states, " Clearly a few minutes may lapse during a telephone call... However, any delay longer than a few minutes would be unacceptable, as would any delay involving call-back..."

In my opinion, this hard line policy may actually compromise the quality of information provided to incident responders.  Obviously, the person most familiar with the shipment cannot be at the emergency response number for the entire duration of a long shipment.  The shipper must thus rely on the written information provided to the person monitoring the emergency response phone number.  If we later provided more detailed information, could we be cited for undue delay?

I'd be interested in the opinions of any transportation experts out there, as well as information regarding whether anyone who provided the required information within 15 minutes was still cited by DOT, State Police, etc.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.

Bill Lipton
liptonw@dteenergy.com