The other day Hazmat Scholar posted a thread about the DOT saying that an electronic ERG did not meet the written emergency response requirements.
I want to add something to that (but don’t want to hijack their thread), so here’s my concern about emergency response information.
(1) Some shippers put it on the package. Some parcel carriers insist on having the shipper attach the DGD to the package itself. So…. If 49 CFR requires the information to be available “away from the package” https://lnkd.in/g5cbF9h2) how does that work?
(2) Some shippers attach an SDS to the package – again, seems like it’s not a great idea to force someone to approach a package to get Emergency Response Info (ERI).
(3) My last pet peeve is since the early 1990’s people write the phone number on the DGD without putting a country code (i.e. “1”) when it’s a US number. So some automated systems don’t even bother to do this. So, yeah, perhaps the 800 number for the shipper in Des Moines actually works in Cambodia… But it seems incomplete to not put the country code in front of the Emergency Phone number
Comments? Two issues here. Phone number and written info.
Wait – one more. Some shippers have said that DOT requires an SDS, and we know that’s not true, but be that as it may, sometimes shippers are shocked when I ask, “Are you sure the SDS you think is required actually has all the ERI required by the DOT in https://lnkd.in/gV_cQfpN) for written emergency procedures?”