The Need for Standardizing the Distribution of Emergency Response Information

Editorial by Russell Bowen

Andy Rooney, from the TV show of 60 Minutes, isn’t the only one with an opinion. Everyone has an opinion on something. Here are some opinions that I have concerning the life endangering topic of hazardous materials or dangerous goods information during a transportation incident or accident. Unless the entire emergency response community demands and receives the best that industry currently can provide, who wins? For all first responders to a transportation emergency scene involving an aircraft or a surface vehicle, one of the first considerations, in my opinion, should be: "Are there any hazardous materials on board and if so, where and how much?" While one of the primary objectives for first responders is to neutralize and contain a hazardous materials spill or incident, the safety and well-being of the responders and others involved in the incident must also be a priority. A way of notifying any emergency responder of critical hazmat information should be available immediately upon demand and automated. An automated Notification to the Pilot in Command (NOTOC) or “NOPIC or Pilot Notification Form (PNF)” or Truck Manifest that has emergency response information from two sources contained on it would certainly fill the bill here. Although there has been much talk and meetings on the subject, including a meeting in Washington D.C., by interested parties, little has been done to resolve the lack of timely, accurate and automated hazmat information to all emergency responders. The first source of information should be from the Emergency Response Guidebook (ERG) that was developed jointly by the US Department of Transportation, Transport Canada, and the Secretariat of Communications and Transportation of Mexico (SCT). The second source is the International Civil Aviation Organization (ICAO) Emergency Response Guidance for Aircraft Incidents involving dangerous goods (known as the ICAO Red Book). For the first responder, these sources of information are essential for not only addressing the incident but also conveying information about protective clothing, evacuation and first aid. Onboard the aircraft, the pilot and crew could be considered the first line of defense involving any type of emergency, including a hazardous material spill or incident, and they are in essence the first responders while the aircraft is in the air. Emergency procedures will differ onboard an aircraft in flight vs. procedures to follow while the aircraft is on the ground. Under the guidance of the International Civil Aviation Organization, the ICAO Red Book has been developed with the assistance of the Dangerous Goods Panel to provide guidance to countries and airlines for dealing with dangerous goods emergencies while the aircraft is in the air.  The crew is supplied information related to the inherent risk, risk to aircraft, risk to occupants, spill or leak procedures, firefighting procedures and additional considerations. On board a truck, the procedures for addressing emergency response are outlined on a Truck Manifest using the Emergency Response Guidebook (ERG), including inhalation hazards procedures and ERIP Name or Contract number if provided. The information made available to all should also include the name of the chemical, the UN identification number, class hazard, the degree of danger known as the UN Packing Group Number, quantity per package and a description of the package and where on the aircraft or truck the package is located.  This information should be immediately available from the airline involved to a first responders, free of charge, by using the world wide web. The entire NOTOC or Truck Manifest form should be made available to be immediately e-mailed to any MAPI-compliant e-mail address anywhere in the world within seconds (terminals, smart phones, airport towers, response vehicles, etc.).  While en-route to the scene of a hazmat incident, a first responder that has a smartphone should receive not only the NOTOC or Truck Manifest via e-mail , but also receive a summary in the front end of that e-mail of all of the dangerous goods onboard the aircraft or truck by position number, reflecting total quantity by class hazard, ERG Guide Numbers as well as emergency response telephone numbers of the emergency response information provider. These opinions are that of just one person. Should there be more consideration given to the topic? Unless the entire emergency response community demands and receives the best that industry can currently provide, who wins?

HM-206F and USG-12 Clarification from IATA

IATA recently published a document regarding the U.S. DOT PHMSA final rule HM-206F. Due to some confusion of accepting dangerous goods declarations by carriers and forwarders, the IATA document provides clarification on Emergency Response Information (ERI).

Essentially, a Registered Name or Contract Number with the Emergency Response Information must appear on the shipper's declaration if the original shipper's name (company name) does not otherwise appear on the shipping document.

For more information, please read the full guidance document published by IATA on HM-206F and USG-12.

Emergency Response Information (HM-206F) - Final Rule by PHMSA

Emergency Response Information

There is a new rule effective on October 1, 2010, concerning emergency response information on hazardous materials shipping papers for USA territorial purposes (into, out of or through USA).

Summary

In this final rule, PHMSA (Pipeline and Hazardous Materials Safety Administration) is amending the Hazardous Materials Regulations to clarify requirements governing emergency response information services provided by arrangement with hazardous materials offerors (shippers). In order to preserve the effectiveness of these arrangements for providing accurate and timely emergency response information, PHMSA is requiring basic identifying information (offeror name or contract number) to be included on shipping papers. This information will enable the emergency response information provider to identify the offeror on whose behalf it is accepting responsibility for providing emergency response information in the event of a hazardous materials incident and obtain additional information about the hazardous material as needed.

Comments

This rule primarily effects shippers by all modes of transporation. If the person responsible for the emergency response information is other than the person listed on the shipping paper (e.g. a third party company like Chemtrec or Chemtel who provides the emergency response information), then the responsible person name or contract number must appear on the shipping as well.

This would appear normally in the Additional Handling block of the Air Shippers Declaration for Dangerous Goods under the telephone number. On a Bill of Lading (BOL), this additional information must appear where it will be readily identified from other information under the telephone number. On a Vessel Shippers Declaration Form, it will normally appear in the Additional Handling block under the telephone number or in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found.

Most carriers (airlines, truck companies, vessel operators) will not have the ability to know when this requirement is to be present on shipping papers. Only the shipper (offeror) will know when this information is required, unless the shipper volunteers the fact on shipping papers that a third party, such as Chemtrec or Chemtel is the emergency response information provider (ERIP). Therefore, in most cases, airlines, trucking companies, and vessel operators will take the emergency response information with or without the "Registered Name or Contract Number" being reflected.

Please use this hyperlink for the full rule HM-206F.