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What are the requirements for a 24-hour number on a shipping document?

This post was originally published in November 2020 and has been updated in January 2023 for accuracy.

Most dangerous goods shippers know that a 24-hour emergency response phone number is required on the shipping paper (declaration), but not everyone fully understands the actual requirements. Did you know that inspectors will actually call the number to ensure you have met the requirement; or that you are actually registered with the provider? Let’s break it down.

The 49 CFR regulations, Part 172.604 require a numeric emergency response phone number including area code.  The phone number must be monitored at all times, including storage incidental to transportation. It must be answered by a person who is knowledgeable of the hazardous material being shipped and have comprehensive emergency response and incident mitigation for the material or has immediate access to a person who has that information. 

This phone number cannot have a call-back. For example, the use of an answering machine, beeper, or general answering service. 

Shippers’ have the option of handling this requirement themselves or through a 3rd party vendor. If they decide to use a 3rd party emergency response phone number, they must register and/or contract with that company in order to do so. Only then, can the provider’s phone number be used.

This requirement is carried over to both air shipments as shown in the IATA Regulations as a state variation USG12.

As the 49 CFR/DOT is the competent authority for ocean shipments originating in the USA, the requirement of 172.604 applies to IMDG shipments as well.

Similarly, Canada has requirements outlined in the Transportation of Dangerous Goods Regulations, Part 3.5. Subparagraph (1)(f) states that the wording “24-Hour Number” or “Numéro 24 heures”, or an abbreviation of these words, followed by a telephone number is required.  

Canada offers service through CANUTEC, however, you must register and receive permission in writing to use their service. Other 3rd party vendors may be used as well.

The requirement continues, as it did for the USA, for both air requirement through state variation CAG09 and ocean, due to Canada/Transport Canada being the competent authority.

If you are unable to meet the requirements of the 24-hour number, as outlined in the regulations, ICC can help. Ask us about the service we offer to meet this requirement.

 

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Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.

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