The National Association of Chemical Distributors (NACD) is recommending that the Pipeline and Hazardous Material Safety Administration (PHMSA) not require the original product offeror to be listed on all downstream shipping papers as part of emergency response telephone numbers and other contact information.
The NACD recommendation is in response to a notice of proposed rulemaking from PHMSA on the emergency response requirement. NACD said requiring the original offeror to be listed on all of the papers would disrupt third-party agreements that chemical distributors commonly have in which supply sources are kept confidential.
To alleviate this concern, NACD asks PHMSA to clarify that it would be adequate to list the contract number for the shipper/emergency response service provider agreement. NACD further recommends that PHMSA require hazardous materials shippers to list their contract numbers with emergency response service providers on their hazmat registration forms in order to assist the agency with enforcement efforts.
PHMSA’s proposal would amend the Hazardous Materials Regulations (HMR) to require that a person who originally offers a hazardous material for transportation and who uses an emergency response service provider to be listed not only on the original shipping paper but also on all subsequent shipping papers. The purpose of the change is to address problems that have arisen when the shipping paper lists the phone number of the emergency response service provider, but no information about the original shipper. According to PHMSA, in some of these cases, the emergency response service provider has been unable to communicate product-specific information.
See the NACD comments at nacd.com.