If you offer for transportation a hazardous material (HazMat) on a shipping paper, bill of lading or hazardous waste manifest (required for both small and large quantity generations of hazardous waste), you must provide an emergency response telephone number for use in the event of an emergency. It appears many shippers/offerors are unaware of their responsibility regarding this matter and rely on the carrier or designated facility to provide the information required by 49 CFR 172.604.

The purpose of the emergency response telephone number is to be a helpful source of information to emergency responders in the event of a HazMat Incident. Therefore the number must be:

• Monitored at all times the hazardous material is in transportation, and;
• Is the number for a person knowledgeable of the HazMat being shipped and has comprehensive emergency response information for the material (Emergency Response Information Provider or ERI Provider) , or,;
• Or has immediate access to a person with such knowledge and information. Telephone numbers that require a call back such as an answering service, answering machine, or beeper will not suffice.

It is important that the emergency response telephone number is clearly visible in the event of an emergency, therefore the number must be written on the shipping paper as follows:

• Immediately following the description of the hazardous material when a different number applies to each hazardous material (Section 9A on the Uniform Hazardous Waste Manifest), or;
• Entered once on the shipping paper by using a larger or differently colored font, highlighting or otherwise setting the number apart. This option can only be used if the number applies to each hazardous material on the shipping paper. Section 3 of the Uniform Hazardous Waste Manifest may be used to fulfill this requirement.

Unfortunately, some shippers and carriers were using the phone numbers of ERI Providers that they had not registered with to provide such service and in an emergency first responders were not able to obtain vital and necessary information from the ERI Provider. For this reason, effective October 1, 2010, some form of identification of the person who has registered with the ERI Provider must be included on the shipping paper. Identification can be a name, contract number or other unique identifier of the ERI Provider for the registrant and it must be near the emergency contact number unless it appears elsewhere on the shipping paper in a prominent, readily identifiable and clearly visible manner. NOTE: The name of the ERI Provider is not required to appear on the shipping document, just their phone number with the identifier given to the registrant.

If the person offering the hazardous material for shipment is also the ERI Provider, their name or some other acceptable means of identification must appear prominently and clearly on the shipping paper. For the uniform hazardous waste manifest, this is accomplished by proper completion of Section 5. If using a third party, it is the responsibility of the person registered with the ERI Provider to ensure they have the current information on the material before it is offered for shipment. This is especially important for hazardous waste shipments as the wastes may be different for each pickup.

49 CFR 172.604(b) can be difficult to understand but the intent is clear. Some information linking the ERI Provider to the person offering the hazardous material for shipment must be clearly visible on the shipping document for the emergency responders to find.

Prior to your next shipment, ensure that you are in compliance by accurately providing this information to your transporter. Significant penalties will be assessed if the emergency response telephone number for shipment of your hazardous material is discovered to be incorrect or incomplete during an emergency or HazMat Incident. You must also ensure proper training of your HazMat employees and the employees of large quantity generators of hazardous waste who handle the waste, prepare it for shipment, or sign the waste manifest.

Because Safeway Industrial Services primarily transports hazardous waste materials, we have concentrated on this portion of the regulations. Other regulations apply to various hazardous materials not considered wastes and for ERI Provider numbers outside the U.S. Please refer to 49 CFR 172.604 for additional information.

For professional hazardous waste transport and other environmental service, please visit Safeway’s website at www.safewayind.com or call 256-492-3704. Let our almost quarter-century of experience work for your company!