A baguette, bottle of wine, and a beret.
Emergency Response Information (ERI) must be immediately accessible to hazardous material and waste drivers, train, flight and vessel bridge personnel. But not the Emergency Response Guidebook (ERG), as many shippers and generators, the ones required to provide the ERI information, believe. Nor does the Federal Motor Carrier Safety Regulations (FMCSR) for drivers.
The ERG is only one of three ways that shippers can provide 49 CFR Department of Transportation (DOT) Hazardous Materials (HMR), ERI. Shippers also have the option of making up their own ERI form in 172.602(a)(1) or attaching a OSHA Safety Data Sheet (SDS) under 172.602(b)(3)(iii). DOT used to recommend the ERG, or at least mention it in their regulations, years ago. Now, the only federal regulation I can find is that Haz-mat team members must “understand” the ERG under 1910.120(q) Emergency response to hazardous substance releases.
Should the ERG be required to accompany all shipments of hazardous materials?
Do emergency responders rely on the carrier's ERG or their own information?
How effective is the ERG in air and marine vessel incidents?
The answers to these questions could have been up to you. Sign up for our DOT/EPA /OSHA Regulation Update Service. Now! You missed the first comment period. Don’t miss the second one in the forthcoming Proposed Rule and its crucial preamble, which explains the regulations in layman's terms. This will precede the final rule, which is then incorporated in the Code of Federal Regulations, (CFR) as law.
Drivers would be in violation in 177.801 if they accepted a shipment without the shipper or generator’s ERI or their own. But it’s never been the carriers or transporters job to provide it, that’s always been the shippers responsibility.
The United States, Mexico and Argentina, all work on the ERG, but I feel that CANUTEC in Canada does most of the heavy lifting. Whenever I’ve called CANUTEC (canutec@tc.gc.ca. tel.613-992-4624) they've been extremely helpful. They answered my question and patiently waited as I brought forth the requested Dangerous Goods Regulations (DGR) information off their websites.
One more thing, all government agencies in Canada are bilingual. So when you have a DGR question, you can also brush up on your French.
Merci beaucoup!
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc
Hazmat.tsp@gmail.com
Text : 610-587-3978