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PHMSA Sends Out a Request for Comments for the 2020 ERG

The Pipeline and Hazardous Material Safety Administration (PHMSA) has requested comments and input for the 2020 ERG. The Federal Register has provided the following details on page two of their May 23 release

Any comments stakeholders and users wish to provide are welcome, but PHMSA is mainly looking for answers to the following questions:

  1. How can PHMSA make the ERG more user-friendly for first responders during the initial response phase of a hazardous materials transportation incident? Please provide examples.
  2. Does ERG2016 effectively emphasize the most useful information for the initial response phase? 
  3. Have you encountered conflicting or ambiguous guidance messages when using the ERG and other sources of technical information?
  4. Are there ways we could improve the White Pages? Sub-points and specifics can be found at the Federal Register link above. 
  5. In the Yellow or Blue Pages, have you found any identification number and/or material name that seems to be assigned to an incorrect Guide number? If so, please note the identification number, material name, and the Guide number, and suggest a new Guide number with your reasons why.
  6. Do the Orange Guide Pages contain recommendations and responses that are appropriate to the material they are assigned to? If not, please explain and recommend a correction.
  7. How could PHMSA change/improve the introduction and description of the Green Pages or any of the tables?  
  8. When calling any of the Emergency Response Telephone Numbers listed in the ERG, have you experienced a busy telephone line, disconnection, or no response? If so, please describe. 
  9. What format(s) of the ERG do you use (hardcopy, electronic, online, mobile applications, etc.), and why?
  10. How often do you use the ERG in a dangerous goods transportation emergency?

Comments should be forwarded to ERGComments@dot.gov. There is no formal deadline but the review of comments will begin in early 2019.

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