Update July 2016: As of July 5, 2016 DOT PHMSA requires all emergency response phone numbers for hazardous materials shipments to be presented using numbers only.
Q. I was told by my carrier that, in addition to listing an emergency response telephone number on my shipping papers, I would also need to write down my emergency provider contract number next to it. Is this true?
A. Not exactly.
Unless specifically exempted, every hazmat shipment that needs shipping papers also needs an emergency response telephone number. This number exists so that emergency responders can access detailed emergency response information (ERI) in the event of an incident involving the hazmat shipment. The document must establish a link between each hazmat entry, the ERI number(s) for that hazmat, and the identity of the person who shipped that hazmat. If the transporter intends to consolidate multiple shipments, then contract numbers come in handy. Here’s how it works:
Any hazmat shipment that requires shipping papers is required to include an emergency response telephone number to help mitigate accidents [49 CFR 172.600(d)]. Thus, most shipments require some sort of telephone number. There is also a list of specific materials at 49 CFR 172.604(d) that will relieve a shipper from having to include an emergency response telephone number, but assuming that a telephone number is required, here are some of the standards that apply to them:
Basic Requirements for Emergency Response Telephone Numbers
Each person who offers hazmat for transportation must provide an emergency response telephone number for use by emergency responders in the event of an incident involving the material. The number must include the area code, and for international numbers the access code, country code, and city code, etc., as appropriate [49 CFR 172.604(a)].
This number must be monitored at all times the hazardous material is in transportation [49 CFR 172.604(a)(1)]. Typically, this means 24 hours a day, 7 days a week.
The telephone number must connect to a person who has immediate access to comprehensive information about the hazardous material [49 CFR 172.604(a)(2)].
Entering the ERI Number on the Shipping Papers
The telephone number must be entered on the shipping papers either “immediately following the description of the hazardous material…” or in “…a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found….” This provision may be used only if the telephone number applies to each hazardous material entered on the shipping paper and if it is indicated that the telephone number is for emergency response information (for example: “EMERGENCY CONTACT: * * *”). Recognized methods of setting the phone number apart to provide for quick and easy recognition include, but are not limited to, “…highlighting, use of larger font or a font that is a different color from other text and information…” [172.604(a)(3)].
The emergency response telephone number must be either “…[t]he number of the person offering the hazardous material for transportation…” or “…[t]he number of an agency or organization capable of, and accepting responsibility for, providing the detailed information required…” When the offeror is also the emergency response provider, the name must either be entered on the shipping paper in a “…prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found…” or “…entered on the shipping paper immediately before, after, above, or below the emergency response telephone number…” [172.604(b)(1)].
Using an Emergency Response Information Provider
When the telephone number is that of a third-party ERI provider, the ERI registrant has three responsibilities:
The registrant must enter the telephone number for the ERI provider on the shipping papers either immediately following the description of the hazardous materials, or in a “prominent, readily identifiable, and clearly visible manner” as required by 49 CFR 172.604(a)(3).
The registrant must provide the ERI provider with “current information on the material before it is offered for transportation.”
The registrant must identify him- or herself on the shipping paper by name, contract number, or other unique identifier assigned by the ERI provider. This identification must be prominent, readily identifiable, clearly visible, and in direct association with the emergency response telephone number [49 CFR 172.604(b)(2)].
However, “[t]he name of the person registered with the ERI provider is not required to be entered on the shipping paper in association with the ER telephone number if the name of the person is entered elsewhere on the shipping paper in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found. Therefore, provided the registrant’s name is already entered elsewhere in this manner, there is no requirement to add the name twice.” [PHMSA Letter Reference No. 10-0029]
For example, if the shipping papers display the company logo at the top of the shipping paper, or the identity and address of the original shipper are clearly described in the front matter of the shipping paper, and the original shipper is the ERI registrant, then the name does not need to be restated in association with the emergency response number.
As always, ERI providers and/or carriers/transporters may have additional requirements or guidelines for the provision of emergency response information in addition to the requirements of the Hazardous Material Regulations.
Consolidated Shipping Papers
Freight forwarders, railroads, vessel operators, and other transportation and logistics service providers may from time to time aggregate several shipments of hazardous materials from different points of origin into a single consignment. When this happens, the handler may create new shipping papers for the new consignment by transcribing information from the original paperwork. When this happens, the connection between the person who originally shipped a material and the ERI number for that material can be lost. Losing this nexus is why PHMSA amended the ERI telephone number regulations in 2009 to require contract numbers or other identification to appear on shipping papers with ERI numbers.