08-03-2006, 02:23 PM #1
Your chance to influence ERG changes
The DOT is revising the Emergency Response Guidebook. Here's your chance to affect any changes you may want to see it the book as a result of your FF experiences. Your valuable comments should be submitted via email to ERG2008@dot.gov.
MORE INFO BELOW!
Subject: Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA), Federal Register: July 19, 2006 [Volume 71, Number 138, Notices: Pages 41071-41073-Docket No. PHMSA-06-24764 Notice No. 06-03] Revision of the Emergency Response Guidebook
Purpose: This notice advises interested persons that Pipeline and Hazardous Materials Safety Administration (PHMSA) is soliciting comments on development of the 2008 Emergency Response Guidebook (ERG2008), particularly from those who have experience using the 2004 Emergency Response Guidebook (ERG2004) during a hazardous materials incident. PHMSA is also soliciting comments on the experiences emergency responders have had obtaining emergency response information during an incident. The ERG2008 will supersede the ERG2004. The development of the ERG2008 is a joint effort involving the transportation agencies of the United States, Canada, and Mexico.
Be Advised: To better ensure emergency responders and provide the public sufficient opportunity to comment on the ERG2008 and this notice, PHMSA's training and outreach program will actively publicize its interest in receiving comments through announcements to emergency responder associations, during training and education seminars, and during activities with State and local government agencies. In addition, PHMSA has established an e-mail address for interested persons to easily submit their comments: ERG2008@dot.gov.
PHMSA solicits comments on ERG user concerns and on the following
1. Have emergency responders experienced a problem of inconsistent guidance between ERG2004 and other sources of technical information? If so, in what way could PHMSA reduce or reconcile the inconsistencies in the ERG2008?
2. Have emergency responders experienced confusion or difficulty in understanding the scope or purpose of the ERG2004? If so, in what way could PHMSA reduce this difficulty in the ERG2008?
3. Have emergency responders experienced confusion or difficulty in understanding how to use the ERG2004? If so, in what way could PHMSA reduce this difficulty in the ERG2008?
4. How could the ``Table of Initial Isolation and Protective Action Distances'' or its introduction be made easier to comprehend and use?
5. In the ``Table,'' does the distinction between day and night protective action distances add useful information for the first responder? How could the distinction be improved?
6. Could the ``List of Dangerous Water-Reactive Materials''
introduced in The 1996 North American Emergency Response Guidebook
(NAERG96) be enhanced or improved?
7. Have emergency responders experienced difficulty understanding the capabilities of chemical protective clothing, and the limitations of structural firefighter's protective clothing in hazardous materials incidents? If so, in what way can PHMSA improve the understanding in the ERG2008?
8. Have any identification numbers (ID Nos.) been assigned incorrectly to a material? If so, what is (are) the name of the material(s)?
9. Has any identification number and/or material been assigned to the ``wrong'' guide? If so, please identify the material and the guide, recommend the correct guide, and state why you believe it should be used.
10. Are the recommendations and responses on each guide appropriate for the material assigned to the guide?
11. Have emergency responders experienced difficulty with legibility of ERG2004's print style, format, or durability?
12. Have emergency response agencies experienced difficulty in obtaining copies of ERG2004 for their vehicles?
13. In addition to the Table of Placards, Rail Car Identification Chart, and Road Trailer Identification Chart, should other pictorial information be included?
14. Are the Table of Placards, Rail Car Identification Chart, and Road Trailer Identification Chart accurate, useful, and easy to use? If not, how could they be improved?
15. Are the terms listed in the Glossary defined satisfactorily?
16. Should additional terms be added to the Glossary?
17. Have you received inaccurate information from any of the numbers listed in the ERG2004? If so, from which company(s)? What was wrong with the information provided? Was this a one-time occurrence? If not, how many times did this occur?
18. Have non-government emergency response telephone number providers delivered adequate information to assist first responders during emergencies? Please provide examples.
19. Should non-government emergency response telephone number providers be audited to assure their capacity to provide adequate and accurate information to first responders?
20. Are there other companies you have used that you consider reliable and would like included in the ERG2008? Who are they and why?
21. When requesting emergency assistance was the response timely?
What do you consider a timely response? In your opinion, what
company(s) did not meet this requirement? How many times did this occur?
22. When calling one of the Emergency Response Telephone Numbers listed in the ERG2004, have you experienced any problems, such as a busy phone line, being disconnected during call, or no response at all?
23. Do you have any additional comments regarding the quality of service and information received from any of the companies listed in the ERG2004 that provide Emergency Response information?
24. Should non-government emergency response telephone numbers continue to be listed in the ERG2008?
25. To be listed in the ERG2008, should non-government emergency response telephone number providers meet specific and verifiable criteria? If yes, please provide examples.
27. If a non-government emergency response telephone number provider does business under several names, should the provider be limited to one listing in the ERG2008?
Any supporting data and analyses provided will enhance the value of the comments submitted and is appreciated.
Instructions: All submissions must include the DOD agency name and docket number or Regulatory Identification Number (RIN) for this notice.
Docket: For access to the docket to read background documents or comments received, go to http://dms.dot.gov
PHMSA POC: Suezett Edwards, Office of Hazardous Materials Initiatives and Training (PHH-50), Pipeline and Hazardous Materials Safety Administration (PHMSA) 400 Seventh Street, SW., Washington, DC 20590-0001, phone number: (202) 366-4900, e-mail: Suezett.firstname.lastname@example.org.
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