Guidebook feedback

Aug. 1, 2006
THE Pipeline and Hazardous Materials Safety Administration (PHMSA) is soliciting comments on the development of the 2008 Emergency Response Guidebook

THE Pipeline and Hazardous Materials Safety Administration (PHMSA) is soliciting comments on the development of the 2008 Emergency Response Guidebook (ERG2008), particularly from those who have experience using the 2004 Emergency Response Guidebook (ERG2004) during a hazmat incident.

PHMSA is also soliciting comments on experiences emergency responders have had obtaining emergency response information during an incident. The ERG2008 will supersede the ERG2004. Development of the ERG2008 is a joint effort involving transportation agencies of the United States, Canada, and Mexico. PHMSA will publicize its interest in receiving comments on the ERG2008 and this notice through its announcements to emergency responder associations, during training and education seminars, and during activities with state and local government agencies. An e-mail address has been established for interested persons to submit their comments: [email protected].

Written comments should be submitted on or before Sept 18, 2006. Submit them identified by the docket number (PHMSA-06-24764, Notice No. 06-03) by any of these methods:

  • Web site: http://dms.dot.gov.

  • Fax: 202-493-2251.

  • Mail: Docket Management System; United States Department of Transportation, 400 Seventh Street SW, Nassif Bldg, Room PL-402, Washington DC 20590-0001.

  • Hand delivery: To the Docket Management System; Room PL-402 on the plaza level of the Nassif Building, 400 Seventh Street SW, Washington DC between 9 am and 5 pm Monday through Friday, except federal holidays.

  • Federal eRulemaking Portal: Go to www.regulations.gov.

PHMSA solicits comments on these questions:

1. Have emergency responders experienced a problem of inconsistent guidance between ERG2004 and other sources of technical information? If so, in what way could PHMSA reduce or reconcile the inconsistencies in the ERG2008?

2. Have emergency responders experienced confusion or difficulty in understanding the scope or purpose of the ERG2004? If so, in what way could PHMSA reduce this difficulty in the ERG2008?

3. Have emergency responders experienced confusion or difficulty in understanding how to use the ERG2004? If so, in what way could PHMSA reduce this difficulty in the ERG2008?

4. How could the “Table of Initial Isolation and Protective Action Distances” or its introduction be made easier to comprehend and use?

5. In the table,' does the distinction between day and night protective action distances add useful information for the first responder? How could the distinction be improved?

6. Could the “List of Dangerous Water-Reactive Materials” introduced in The 1996 North American Emergency Response Guidebook (NAERG96) be enhanced or improved?

7. Have emergency responders experienced difficulty understanding the capabilities of chemical protective clothing, and the limitations of structural firefighter's protective clothing in hazmat incidents? If so, in what way can PHMSA improve the understanding in the ERG2008?

8. Have any identification numbers been assigned incorrectly to a material? If so, what is (are) the name of the material(s)?

9. Has any identification number and/or material been assigned to the “wrong” guide? If so, please identify the material and the guide, recommend the correct guide, and state why you believe it should be used.

10. Are the recommendations and responses on each guide appropriate for the material assigned to the guide?

11. Have emergency responders experienced difficulty with legibility of ERG2004's print style, format, or durability?

12. Have emergency response agencies experienced difficulty in obtaining copies of ERG2004 for their vehicles?

13. In addition to the Table of Placards, Rail Car Identification Chart, and Road Trailer Identification Chart, should other pictorial information be included?

14. Are the Table of Placards, Rail Car Identification Chart, and Road Trailer Identification Chart accurate, useful, and easy to use? If not, how could they be improved?

15. Are terms listed in the glossary defined satisfactorily?

16. Should additional terms be added to the glossary?

Questions regarding the emergency response telephone numbers listed in the ERG2004:

17. Have you received inaccurate information from any of the numbers listed in the ERG2004? If so, from which company(ies)? What was wrong with the information provided? Was this a one-time occurrence? If not, how many times did this occur?

18. Have non-government emergency response telephone number providers delivered adequate information to assist first responders during emergencies? Please provide examples.

19. Should non-government emergency response telephone number providers be audited to assure their capacity to provide adequate and accurate information to first responders?

20. Are there other companies you have used that you consider reliable and would like included in the ERG2008? Who are they and why?

21. When requesting emergency assistance, was the response timely? What do you consider a timely response? In your opinion, what company(ies) did not meet this requirement? How many times did this occur?

22. When calling one of the Emergency Response Telephone Numbers listed in the ERG2004, have you experienced any problems, such as a busy phone line, being disconnected during call, or no response at all?

23. Do you have any additional comments regarding the quality of service and information received from any of the companies listed in the ERG2004 that provide emergency response information?

24. Should non-government emergency response telephone numbers continue to be listed in the ERG2008?

25. To be listed in the ERG2008, should non-government emergency response telephone number providers meet specific and verifiable criteria? If yes, please provide examples.

26. If a non-government emergency response telephone number provider does business under several names, should the provider be limited to one listing in the ERG2008?