When do you need a 24 hour Emergency Response Phone Number?
It is common knowledge that most Hazmat (DG) shipping papers (declarations) require a 24-hour emergency response telephone (ERT) number per the US Hazardous Material Regulations (HMR) codified in 49-CFR, Part 172.604. However, this requirement is commonly misunderstood – especially with recent changes to the HMR. Here are some of the basic questions and answers regarding this requirement:
When is an ERT number required?
The number is required for all modes of transport – air, ocean, highway and rail – whenever a shipping paper (declaration) is required – with some exceptions such as limited quantities, consumer commodities and others (see SOURCE 49-CFR, Part 172.604 for complete list of exceptions).
Who is the actual party that must be available to answer if this number is called?
The number must be of the party taking responsibility for providing this function, which can be either the shipper or a third-party emergency response information provider (ERI provider) such as Chemtrec, Infortrac, or Chemtel or other responsible party.
Where is this number required to be shown?
The number must be entered on the shipping paper so that it is easily found such as in bold type or highlighting, and easily identified with a description such as “Emergency Contact” or similar.
What information is the ERI provider responsible to provide?
The ERI provider must be, “knowledgeable of the hazardous material being shipped and have comprehensive emergency response and incident mitigation information for that material, or have immediate access to a person who possesses such knowledge and information.”
If the shipper uses a third-party ERI provider, what additional requirements apply?
“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,” and, “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.”
Does the ERI provider have to be located in the US?
Although this is a US DOT requirement, the ERI provider can be located within the US or a foreign country. For example, if a company has its headquarters overseas, they can use an ERT number in that country.
What is the correct format for the ERT number for domestic dialing?
For domestic ERT number dialing, it is important to include all the dialing digits, such as 1 + AREA CODE + NUMBER, so that anyone can walk up to a telephone and dial without making a mistake. Also, toll-free numbers such as 1-800 numbers are acceptable.
What is the correct format for the ERT number for international dialing?
If the ERI provider is located abroad, again it must include all the dialing digits to complete the call, such as US EXIT CODE (O11) + COUNTRY CODE + CITY CODE + NUMBER.
What if the ERT number is in the US for an international shipment?
Remember, this is a US law, so a foreign country will probably not initiate an international call back to the US in case of an emergency involving as Hazmat/DG shipment. Also, different countries have different exit codes, so attempting to provide a number back to the US may be a hindrance. Therefore, it is best not to provide one at all.