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RE: DOT shipping topic: Emergency response number
It CANNOT be a pager, voice mail, answering machine or traditional answering service (like your family doctor might use). A system similar to CHEMTREC, where the manufacturer or shipper supplies "ring down" lists to the service of knowledgeable people, and can conference or bridge the responder (me, sometimes) to that person rapidly, is acceptable.
The text of a US DOT letter on the issue:
Ref. No. 00-0280
Mr. Andrew C. Rymer
Transportation Consulting Services
Post Office Box 592
Fulton, MD 20759
Dear Mr. Rymer:
This responds to your letter requesting clarification on the term "immediate access" as used in § 172.604
of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
As provided by § 172.604
a person who offers a hazardous material for transportation must provide an emergency response telephone number. It must 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. You are correct that the term "immediate access" is not defined in the HMR. However, the term is intended to indicate that the emergency response information must be provided to a responder with no undue delay. Clearly, a few minutes may lapse during a telephone call while the person answering the emergency response phone number locates specific information on a particular product or contacts a person to provide such information. However, any delay longer than a few minutes would be unacceptable, as would any delay involving call-back, such as would be necessary if the person answering the
!
e!
mergency response telephone number had to use a pager to contact someone with the specific knowledge about the product in question.
We are aware of the Nuclear Regulatory Commission's (NRC) Information Notice 92-62 that was issued to increase awareness that licensees must be prepared to respond promptly with the information needed, when called. The NRC provided its opinion 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 response situations, a delay of 15 minutes would be unacceptable.
I hope this information is helpful.
Sincerely,
Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
Capt. Bruce Bugg
Special Projects Coordinator
Law Enforcement Division
Georgia Department of Motor Vehicle Safety
P.O. Box 80447
Conyers, GA 30013-8047
Phone: 678.413.8825
Fax: 678.413.8832
e-mail: obbugg@dmvs.ga.gov
"Making the simple complicated is commonplace; making the complicated simple, awesomely simple, that's creativity." -- Charles Mingus (Musician, 1922-1979)
-----Original Message-----
From: owner-radsafe@list.vanderbilt.edu
[mailto:owner-radsafe@list.vanderbilt.edu]On Behalf Of Engelbretson,
David A.
Sent: Friday, March 26, 2004 10:57
To: 'amrso@mcw.edu'; radsafe@list.vanderbilt.edu
Subject: DOT shipping topic: Emergency response number
Dear Colleagues,
CFR 172.604 indicates that the ER number must be answered by a person
knowledgeable about mitigation information..... or by a person who has
immediate access to a knowledgeable person.
Could anyone interpret "immediate access" for me ?
Thank you in advance.
Dave
David A. Engelbretson, MS, RRPT, CHMM
Radiation Safety Officer
Methodist Hospital
6565 Fannin, Suite STB1-12D
Houston, Texas 77030
Phone: 713-441-4553
Fax: 713-441-0990
-----------------------------------------
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