What might be considered to be a reasonable response to and emergency telephone number? (domestic tanker journeys only)

CDG Regs at Regulation 6 and schedule 1 requires that a telephone number where specialist advice concerning the dangerous goods in question can be obtained in English at any time during carriage should be displayed.

This is a GB domestic requirement and does not apply to vehicles properly displaying HIN plates, that is, on international journeys.

The regulations offer no guidance as to what might be considered to be a reasonable response, but this is discussed below.

Arranging for specialist advice to be available out of normal working hours is difficult and carriers or consignors often retain external contractors to:

  • Provide the specialist advice, or
  • Act as an initial point of contact, with enquiries being referred to appointed 'duty officers' within the company.

Inspectors are advised that the above arrangements are acceptable provided the advice at the point of contact is appropriate, prompt and involves only one referral.

The Chemsafe Liaison Group when it was formed considered and agreed the parameters against which an informed response was deemed to be reasonable. These were included in a CIA publication, "Chemsafe - Assistance in Chemical Distribution Emergencies." The key points are summarised below,

  • The initial call to the number should be picked up as might be expected of a normal telephone call.
  • Thereafter, companies should aim to respond by providing,
    • Product based information within 10 minutes of receipt of the initial request, and
    • Any further technical information and advice, as necessary, within 30 minutes.

Inspectors encountering vehicles carrying dangerous goods in tanks should consider enforcement action where there is:

  • No telephone number displayed (but note alternative provision in Schedule 6 para 5(2)
  • No response, or
  • A seriously inadequate response (ie significantly worse than that indicated above)

When checking the availability of specialist advice as part of a roadside check, by telephoning the displayed number, inspectors should ask for information based on all available information relating to the load (eg the UN number(s) and Emergency Action Code which are displayed). Where UN numbers are generic ("NOS") there may be a need to supply any other information that is available in the documentation to get more detailed advice.

It is not necessary to imagine a scenario where that information is not available.

Inspectors should make the purpose of the call clear. This will avoid any misunderstanding that the call could be related to an actual emergency and enable the person answering the call to do so in the correct context.

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Updated 2019-11-08