On March 17, 2019

Two Reasons Shippers Should Review Their 49 CFR Emergency Number

Requests for an emergency telephone number for the transport of hazardous goods took place more than two decades ago. In America regulation, 49 CFR § 172.604 requires companies that transport hazardous goods to have a valid 24-hour 49 CFR emergency number.

Companies exporting any products that are hazardous or contain hazardous goods and are subject to regulation 49 CFR § 172.604 should abide by this regulation.  With more inspections and spot checks by authorities, exporters from Asia and the rest of the world to the USA need to review their 49 CFR emergency response telephone number set up.

49 CFR §172.604 regulation highlights

Below are some important highlights from section 172.604 of the USA’s 49 CFR regulation.

(a) A person who offers a hazardous material for transportation must provide a numeric emergency response telephone number, including the area code, for use in an emergency involving the hazardous material. For telephone numbers outside the United States, the international access code or the “+” (plus) sign, country code, and city code, as appropriate, that are needed to complete the call must be included.

The telephone number must be –

(1) Monitored at all times the hazardous material is in transportation, including storage incidental to transportation;

(2) The telephone 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. A telephone number that requires a call back (such as an answering service, answering machine, or beeper device) does not meet the requirements of paragraph (a) of this section

(b) The telephone number required by paragraph (a) of this section must be –

(1) The number of the person offering the hazardous material for transportation when that person is also the emergency response information provider (ERI provider). The name of the person, or contract number or other unique identifier assigned by an ERI provider, identified with the emergency response telephone number must be entered on the shipping paper immediately before, after, above, or below the emergency response telephone number unless the name 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; or

(2) The number of an agency or organization capable of, and accepting responsibility for, providing the detailed information required by paragraph (a)(2) of this section. The person who is registered with the ERI provider must ensure that the agency or organization has received current information on the material before it is offered for transportation. The person who is registered with the ERI provider must be identified by name, or contract number or other unique identifier assigned by the ERI provider, on the shipping paper immediately before, after, above, or below the emergency response telephone number in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found, unless the name or identifier is entered elsewhere in a prominent manner as provided in paragraph (b)(1) of this section.

Above is just part of the 49 CFR § 172.604 regulation of which you can find the full version here.

Analyze the following two important reasons why you should review your 49 CFR emergency number!

Reason 1: The number must be monitored at all time and without call back function

Review your current set up and verify if you are able to fulfill this requirement. A personal mobile phone number is not a proper 49 CFR emergency telephone number, for example, as it cannot be monitored at all time and often uses a call back function such as voicemail. Toll-free numbers are also not acceptable for shipments to the USA. Is your current emergency number always available and switched on 24/7?

Reason 2: You need immediate knowledge of the hazardous goods

The person receiving the call needs to have immediate access to product data and need to be knowledgeable of the hazardous goods being shipped. It is also expected that support will be provided in English which could be difficult when product knowledge is required.  Imaging a shipper from Taiwan that does not master English and is called to handle an emergency, for example.

Outsourcing your 49 CFR emergency number is the way to go!

The above two reasons indicate that for many companies it is not easy to provide a valid 24/7 emergency response helpline that meets the 49 CFR § 172.604 requirements.  Not having a proper set up can result in various costly problems, such as shipments being blocked at the port due to non-compliance.

We, therefore, recommend you to outsource your 24/7 emergency response helpline to a professional company that is staffed by trained chemists with hazardous goods knowledge that can provide support in dealing with emergencies.  Outsourcing will also provide a range of local telephone numbers and allow support in various international languages.

 

Let’s us know if you like to get more information and would like to subscribe to an outsourced 49 CFR emergency number.  Complete our form upon exit or send an email to info@ener8.com.

 

 

Photo Credit: Vidar Nordli-Mathisen on Unsplash

  • By Rudi Stalmans  0 Comments   
  • Chemical Emergency Response, HSEQ, Incident Reporting

    0 Comments

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