WHAT`S INSIDE

®
WINTER 2009 - 2010
HAZARDOUS MATERIALS: Revision
of Requirements for Emergency Response Telephone Numbers
In the October 19, 2009 Federal Register (74FR53413) the Pipeline and
Hazardous Materials Safety Administration (PHMSA) published a final
rule on the revision of requirements for emergency response telephone
numbers [Docket No. 2006-26322 (HM-206F)].
SUMMARY: In this final rule, PHMSA is amending the Hazardous Materials Regulations to clarify requirements governing emergency response
information services provided by arrangement with hazardous materials
offerers (shippers). In order to preserve the effectiveness of these
arrangements for providing accurate and timely emergency response
information, PHMSA is requiring basic identifying information (offerer
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. DATES: Effective Date: The effective date of this final
rule is October 1, 2010. Voluntary Compliance Date: PHMSA is authorizing immediate voluntary compliance beginning last November 18, 2009.
In this rulemaking PHMSA is requiring the offeror who is registered with
the ERI (Emergency Response Information) provider, as reflected by the
provider’s telephone number on shipping papers, to be identified on the
shipping paper. Specifically, PHMSA is revising the HMR to:
1. Require an offerer who has made an arrangement with an ERI provider
(such as INFOTRAC) to be identified on the shipping paper in clear association with the emergency response telephone number. In response to
comments, PHMSA is clarifying that if the name of the offeror is prominently and clearly listed elsewhere on the shipping paper, it need not also
be listed in association with the emergency response telephone number.
For example, if your shipping paper has a company logo, company name
and address, etc. elsewhere on the document, it does not need to be
re-listed. However, if your company name is NOT listed in another location, it MUST be listed with the ERI telephone number.
continued on Page 2
WHAT’S INSIDE
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WELCOME
ABOARD!
Dyno-Wash Cleaning Systems
Pilot International
Drexel Chemical Company
GE Homeland Protection
Carmeuse Lime & Stone
Advanced Battery Systems
Alligare, LLC
Control Solutions, Inc
Babcock Power
Environmental
WW Williams Distribution
Jarp Industries
And hundreds of others who
have placed their trust and
confidence in INFOTRAC
MSDS Management Programs - Call INFOTRAC for a quote or to discuss your specific needs - 1-800-468-1263
Page 2
HAZARDOUS MATERIALS: Revision of Requirements for
Emergency Response Telephone Numbers
continued fron Page 1
For Example, "ABC Company ER Company - INFOTRAC 24-Hour Number: 1-800-535-5053".
NOTE: On Federal Register page 53423, INFOTRAC believes that the US DOT incorrectly published the Final
Rule by stating that “The person who is registered with the emergency response provider must be identified by
name or contract number on the shipping paper immediately before, after, above, or below the emergency
response telephone number in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found.” As you can see, they left out the text “unless the name is entered elsewhere on the shipping paper in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found;” which they mention in the preamble.
INFOTRAC has contacted the US DOT Help Desk (800-467-4922 option 1) on this 3 times and we have
received mixed reactions. It is possible that the US DOT will release a correction to this Final Rule to correct this
potential oversight. Until a correction, if any, is issued, INFOTRAC recommends putting your company name
next to INFOTRAC’s emergency response (ER) telephone number unless your company name is immediately
adjacent to our ER telephone number.
2. Clarify that any person preparing a subsequent shipping paper for continued transport of a hazardous materials shipment must include the offeror’s name (whether the original or subsequent offerer) that is the registrant
for the ERI provider and that will be in use for the continued transportation of the shipment. The name of the
original or subsequent offeror or its contract number with the ERI provider must be included on the shipping
paper. If the original or subsequent offeror is not continuing as the registrant with the ERI provider, the person
preparing subsequent shipping papers must insert and identify by name its own valid emergency response telephone number conforming to the requirements in Subpart G of Part 172. Said differently, the company that subscribes to INFOTRAC services would continue to be listed on the shipping paper, when required.
3. Clarify that the person answering the ERI provider’s telephone number transmits all written information in
English. All INFOTRAC correspondence is done in English.
4. Clarify that international telephone numbers used to meet the emergency response telephone number
requirement must include the international access code or a ‘‘+’’ sign as a placeholder for the international
access code, country code, and city code as appropriate. Please note: this section refers only to international
transportation. The INFOTRAC labels are being updated to meet this requirement by its mandatory compliance
date and will read, "INFOTRAC 24-hr number: + 1-352-323-3500"
5. Clarify the term ‘‘clear association’’ with respect to the placement of the identity of the registrant of the ERI
provider.
6. Clarify the current requirement for the emergency response telephone number to be provided on the shipping
paper in a ‘‘clearly visible’’ location.
7. Clarify that the emergency response telephone number requirements do not apply to transport vehicles or
freight containers containing lading that has been fumigated and displays the FUMIGANT marking, as required
by 53416 Federal Register / Vol. 74, No. 200 / Monday, October 19, 2009 / Rules and Regulations § 173.9 of
the HMR, unless other hazardous materials are present in the cargo transport unit.
The amendments in this final rule are intended to fill a gap that was unforeseen when PHMSA initially adopted
these requirements in 1989 under Docket HM–126C (54 FR 27138, 06/27/89). The amendments in this final
rule will help to ensure that transportation workers and emergency response personnel are provided with accurate and timely information about the hazardous materials involved in a transportation accident or other emergency. This final rule will also serve to eliminate delays in transportation due to lack of such information, and
eliminate problems created when compliance personnel are not able to verify emergency response telephone
numbers. In other words, it allows INFOTRAC responders to more quickly verify the shipper, thereby providing
quicker emergency response information.
Page 3
OSHA Hazard Communication (continued)
The format for the InfoBulletin is changing! From this
issue forward, INFOTRAC will be focusing on the
Federal Register and the ongoing changes to the
regulations affecting the safe transport of hazardous
materials. The Federal Register is published by the
Office of the Federal Register, National Archives
and Records Administration (NARA).The Federal
Register is the official daily publication for rules,
proposed rules, and notices of Federal agencies
and organizations, as well as executive orders and
other presidential documents. It is updated daily by
6 a.m. and is published Monday through Friday,
except Federal holidays.
INFOTRAC scrubs the Federal Register on a daily
basis, keeping our clients as up to date as possible
on the regulations. Drastic, complicated, and/or vital
information published will be commented on by one
of INFOTRAC's regulatory agents. Other articles will
be published in the InfoBulletin exactly as they
appeared in the Federal Register. Certain features
of the InfoBulletin, such as Welcome Aboard and
Looking Ahead will remain in the new format.
Be safe,
Andie Denk Feil, MBA
Editor
OSHA Hazard Communication
In the September 30, 2009 Federal Register (Vol.
74, No. 188), the Occupational Safety and Health
Administration (OSHA), in conjunction with the
Department of Labor (DOL), published a proposed
rule and a request for comments regarding hazard
communication [Docket No. OSHA-H022K-20060062 (formerly Docket No. H022K)]. On November
5, 2009, OSHA & DOL issued a proposed correction
to this proposed rule which corrects eight errors,
four in the preamble and four that appear in Appendix A: Table A.1.1, Table A.1.2, Table A.2.3, and
Table A7.1.
SUMMARY: OSHA is proposing to modify its existing Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labeling of
Chemicals (GHS). OSHA has made a preliminary
determination that the proposed modifications will
improve the quality and consistency of information
provided to employers and employees regarding
chemical hazards and associated protective measures. The Agency anticipates this improved information will enhance the effectiveness of the HCS in
ensuring that employees are apprised of the chemical hazards to which they may be exposed, and in
reducing the incidence of chemical-related occupational illnesses and injuries.
The proposed modifications to the standard include
revised criteria for classification of chemical hazards; revised labeling provisions that include
requirements for use of standardized signal words,
pictograms, hazard statements, and precautionary
statements; a specified format for safety data
sheets; and related revisions to definitions of terms
used in the standard, requirements for employee
training on labels and safety data sheets. OSHA is
also proposing to modify other provisions, including
standards for flammable and combustible liquids,
process safety management, and most substancespecific health standards, to ensure consistency
with the modified HCS requirements. As this is a
proposed rule, not a final rule, INFOTRAC will be
closely monitoring the proceedings. If the need
arises, we will pass on necessary information as it
becomes available.
OSHA will be accepting comments through December 29, 2009. Below is a list of the various methods
for commenting on the proposed rule, including due
dates, addresses, and instructions.
DATES: Written comments, including comments on
the information collection determination described in
Section VIII of the preamble (OMB Review under
the Paperwork Reduction Act of 1995), must be submitted by December 29, 2009.
Facsimile and electronic transmissions: Comments
must be sent by December 29, 2009.
Informal public hearings. The Agency will schedule
an informal public hearing on the proposed rule. The
location and date of the hearing, procedures for
interested parties to notify the Agency of their intention to participate, and procedures for participants to
submit their testimony and documentary evidence
will be announced in the Federal Register.
continued on Page 4
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OSHA Hazard Communication
(continued from Page 3)
ADDRESSES: Written comments. You may submit
comments by any of the following methods: Electronically: You may submit comments electronically
at http://www.regulations.gov, which is the Federal
e-Rulemaking Portal. Follow the instructions on-line
for making electronic submissions. Fax: If your submissions, including attachments, are not longer than
10 pages, you may fax them to the OSHA Docket
Office at (202) 693–1648.
Mail, hand delivery, express mail, messenger or
courier service: You must submit three copies of
your comments to the OSHA Docket Office, Docket
No. OSHA–H022K–2006–0062, U.S. Department of
Labor, Room N–2625, 200 Constitution Avenue,
NW. Washington, DC 20210. Deliveries (hand,
express mail, messenger and courier service) are
accepted during the Department of Labor’s and
Docket Office’s normal business hours, 8:15 a.m.4:45 p.m., E.T.
INSTRUCTIONS: All submissions must include the
Agency name and the docket number for this rulemaking (Docket No. OSHA–H022K–2006–0062). All
comments, including any personal information you
provide, are placed in the public docket without
change and may be made available online at
http://www.regulations.gov. Therefore, OSHA cautions you about submitting personal information
such as social security numbers and birthdates.
SUPPLEMENTARY INFORMATION: The preamble
to the proposal to modify the Hazard Communication Standard includes a review of the events leading to the proposal, a discussion of the reasons why
OSHA believes these modifications are necessary,
the preliminary economic and regulatory flexibility
analysis for the proposal, and an explanation of the
specific provisions set forth in the proposed standard. The discussion follows this outline:
I. Introduction
II. Issues
III. Events Leading to the Proposed Modifi............... ..cations to the Hazard Communication
.............. . ..Standard
IV. Overview and Purpose of the Proposed
..................Modifications to the Hazard Communi..................cation Standard
V.
.............. ..
.............. ..
VI.
VII.
.............. ..
VIII.
.............. ..
IX.
X.
XI.
XII.
.............. ..
XIII.
XIV.
XV.
.............. ..
.............. ..
Need and Support for the Proposed
Modifications to the Hazard
Communication Standard
Pertinent Legal Authority
Preliminary Economic Analysis and
Initial Regulatory Flexibility Analysis
OMB Review Under the Paperwork
Reduction Act of 1995
Federalism
State Plans
Unfunded Mandates
Protect Children From Environmental
Health and Safety Risks
Environmental Impacts
Public Participation
Summary and Explanation of the
Proposed Modifications to the Hazard
Communication Standard
(a) Purpose
(b) Scope
(c) Definitions
(d) Hazard Classification
(e) Written Hazard Communication
............
.. ..Program
(f) Labels & Other Forms of Warning
(g) Safety Data Sheets
(h) Employee Information & Training
(i) Trade Secrets
(j) Effective Dates
(k) Other Standards Affected
(l) Appendices
XVI. References
XVII. Authority and Signature
XVIII. Proposed Amendments
Remember, this is an OSHA proposed rule. Items
such as hazard class and labeling are from a workplace safety perspective, not transportation. However, INFOTRAC will work with all clients who have
questions or concerns about compliance.
It is with heavy hearts that we
report the sad loss of Infotrac’s
finest, Steve Cunningham.
He will be greatly missed by
his all his family, friends and
co-workers.
Steve is survived by his wife Kim and daughter
Kaylee. Please join us in remembering our dear
friend Steve Cunningham.
Page 5
Since our last publication, the
Pipeline and Hazardous Materials
Safety Administration (PHMSA)
published a notice of approval
[Docket No. PHMSA–2009–0253;
Notice No. 09–4] on August 25,
2009 and a safety advisory
[Docket No. PHMSA–2009–0310;
Notice No. 09–05] on October 7,
2009 regarding the transportation
of lithium batteries.
NOTICE OF APPROVAL SUMMARY: PHMSA is authorizing
persons who offer lithium metal
and lithium ion cells and batteries
for transportation in commerce,
and persons who transport lithium
metal and lithium ion cells and
batteries
in
commerce,
to
describe those articles in the
same manner as recently adopted
in
international
regulations.
PHMSA will consider adopting
these alternate shipping descriptions into the Hazardous Materials
Regulations at a future date.
DATES: Effective Date: This
notice of approval is effective
August 25, 2009.
ADDITIONAL
INFORMATION:
PHMSA has concluded that
assigning the same shipping
descriptions to both lithium metal
and lithium ion batteries, which
are regulated differently based on
differences in chemistry, functionality, and behavior when exposed
to a fire, causes significant problems in acceptance procedures
for carriers and may unnecessarily hinder or delay the transportation of these products. While the
HMR permit the use of the ICAO
Technical Instructions as well as
the International Maritime Dangerous Goods Code (IMDG Code)
for domestic transportation when a portion of
the transportation is by
aircraft or vessel, subsequent domestic transportation of packages containing
lithium batteries remains difficult.
PHMSA is currently working on a
rulemaking intended to enhance
the safe transportation of lithium
batteries. As part of this rulemaking, PHMSA is considering adoption of the international shipping
descriptions for lithium metal and
lithium ion batteries.
To facilitate commerce, however,
PHMSA believes shippers should
be permitted to use the international lithium battery shipping
descriptions for the domestic
transportation of lithium batteries
even though the shipping descriptions have not been adopted into
the HMR. In accordance with §
172.101(l)(2), PHMSA is authorizing use of the lithium battery shipping descriptions (i.e., the lithium
battery
hazardous
materials
descriptions and UN ID numbers)
that have been adopted into dangerous goods lists in the international regulations as alternatives
to the lithium battery hazardous
materials descriptions and UN
identification numbers currently
authorized in the HMT, effective
as of the date of publication of this
notice in the Federal Register.
Effective August 25, 2009 a shipper may now use EITHER the
domestic or international UN
number and proper shipping
name to describe lithium batteries
REGARDLESS of the mode of
transportation. Below is a chart
comparing the domestic and international information.
Please call INFOTRAC at 1-800535-5053 if you require further
assistance with this notice of
approval.
SAFETY ADVISORY SUMMARY:
The Pipeline and Hazardous
Materials Safety Administration
(PHMSA) and the Federal Aviation Administration (FAA) are
alerting shippers and carriers to
the importance of transporting
lithium batteries safely. PHMSA
and FAA are concerned that many
persons who ship lithium batteries
do not recognize the hazards
posed by these batteries during
transportation. They are issuing
this advisory guidance to
(1) Inform persons of recent aviation incidents involving fires
aboard both passenger and cargo
aircraft and the potential hazards
that shipments of lithium batteries
may present while in transportation, (2) provide information concerning the current requirements
for the transportation of lithium
batteries and (3) inform persons
of the actions they have taken to
date and plan to take in the future
to address the hazards of these
batteries.
SUPPLEMENTARY INFORMATION: Lithium batteries are considered hazardous materials in
transportation because they present both chemical (e.g., flammable electrolytes) and electrical
hazards. If not safely packaged
and handled when transported,
lithium batteries can become dangerous. Defective batteries or
batteries that are misused,
mishandled, improperly packaged, improperly stored, improperly manufactured, or overcharged can overheat and ignite
and, once ignited, fires can be
especially difficult to extinguish.
Overheating has the potential to
create a thermal runaway, a chain
reaction leading to self-heating
and release of the battery’s stored
energy. Fires in aircraft can result
in catastrophic events presenting
continued on Page 6
Page 5
continued from Page 5
unique challenges not encountered in other transport modes.
II. Recent Transportation Incidents:
Since 1991, they have identified
over 40 air transport-related
incidents involving lithium batteries and devices powered by
lithium batteries. A list of these
incidents can be found on the FAA
Web
site
at:
http://www.faa.gov/about/office_o
rg/headquarters_offices/ash/ash_
programs/hazmat/aircarrier_info/
media/Battery_incident_chart.pdf.
These incidents occurred aboard
passenger aircraft and cargo
aircraft, prior to loading batteries
aboard an aircraft, and after
batteries were transported by air.
Many of the incidents were
directly related to a lack of awareness of the required safety measures applicable to shipments of
lithium batteries or because passengers failed to follow preventative measures to protect batteries
from short circuit or damage. The
following examples are just a
sample of the incidents that have
occurred.
On September 9, 2009 a passenger flight declared an emergency
after a passenger attempted to
hand the flight attendant a
carrier-provided personal electronic device (PED). The PED was
dropped and upon impact with the
cabin floor the battery pack
sparked and began smoking. Two
flight attendants extinguished the
fire with water.
On August 25, 2009 DOT
received information related to a
smoking and burning package
that was discovered at a Medford,
Massachusetts sorting facility.
Upon inspection, the consignment
was discovered to contain 30
individual
batteries
grouped
together in six or seven battery
packs. The package contained
lithium batteries that were shipped
as general cargo. There were no
markings or labels on the outer
package indicating the material
was a hazardous material.
On August 14, 2009 after landing
the aircraft, the flight crew
received a warning indicating
smoke in the forward cargo compartment. Initial indications are
that a fire originated with a shipment of approximately 1,000
e-cigarettes, each containing a
lithium metal battery. There were
no markings or labels indicating
the materials posed a specific
hazard or contained lithium batteries.
On July 15, 2009 one of several
related packages transported
from Romulus, Michigan was
discovered emitting smoke and
smoldering upon arrival in Santo
Domingo, Dominican Republic.
Upon inspection, the package
was found to contain numerous
loose lithium-ion cell phone
batteries haphazardly packed with
no apparent measures to protect
against short circuits or overheating. Package documentation
indicated, ‘‘used batteries—non
haz.’’
Persons who violate the HMR
may be subject to significant civil
penalties and/or criminal fines and
imprisonment. In determining the
amount of a civil penalty the
following factors will be determined: (1) The nature, circumstances, extent, and gravity of the
violation; (2) with respect to the
violator, the degree of culpability,
and history of prior violations, the
ability to pay, and any effect on the
ability to continue to do business;
and (3) other matters that justice
requires. Maximum civil penalties
may be imposed of up to $50,000
per violation or $100,000 per
violation if a death, serious illness,
or severe injury occurs to a
person or substantial destruction
of property. Potential criminal penalties include fines of up to
$500,000 and/or ten years in jail.
In a recent enforcement case,
PHMSA assessed a total civil penalty of $360,000 for multiple violations of the HMR relating to the
improper shipment of used batteries for recycling or disposal. To
date, FAA has closed over 75
investigations concerning battery
violations observed in air transport and has collected over
$1,000,000 in civil penalties.
The requirements for the safe
transport of lithium batteries are
complex and ever-changing. If
your company would like training
on this or any other hazardous
material transportation topic,
please contact INFOTRAC'S
training department at 1-800535-5053.
Chemical Oxygen Generators
Page 7
The Pipeline and Hazardous Materials Safety Administration (PHMSA) published a direct final rule [Docket No.
PHMSA–2009–0238 (HM–224G)] on October 15, 2009 regarding chemical oxygen generators.
SUMMARY: This direct final rule amends the Hazardous Materials Regulations to revise the quantity limitation
from 25 kg ‘‘gross’’ to 25 kg ‘‘net’’ for packages of chemical oxygen generators transported aboard cargo
aircraft only. The intended effect of this rule is to provide regulatory relief by raising the quantity threshold for
shipments of chemical oxygen generators transported aboard cargo aircraft only. This action is necessary to
address difficulties concerning implementation and compliance with the requirements for the transportation of
chemical oxygen generators in outer packagings meeting certain flame penetration resistance standards and
thermal protection capabilities, as evidenced by comments received from the hazardous materials industry and
other interested parties. The amendment contained in this rule is a minor substantive change, in the public
interest, and unlikely to result in adverse comment. This final rule allows shippers to pack up to 25 kg of chemical oxygen generators in one package, without regard to the weight of the actual outer package. This provides
a great deal of relief for the shipper, as some of the new compliant containers can weigh up to 66 kg when
empty. Information about the initial final rule and the subsequent advisory alert is provided below.
DATES: This direct final rule is effective November 16, 2009, unless an adverse comment or notice of intent to
file an adverse comment is received by November 16, 2009. PHMSA will publish in the Federal Register a
timely document confirming the effective date of this final rule.
ADVISORY ALERT: This advisory is intended to alert persons that after September 30, 2009, cylinders of compressed oxygen and other oxidizing gases and packages of chemical oxygen generators must be placed in
outer packagings that meet certain flame penetration and thermal resistance requirements when transported
aboard an aircraft.
PHMSA adopted the outer packaging requirement in a final rule developed in cooperation with the Federal
Aviation Administration and published January 31, 2007.
PHMSA indicated in a subsequent September 28, 2007 final rule that PHMSA and FAA planned to closely
monitor the availability of the required outer packagings and would consider an extension of the October 1,
2009 compliance date if PHMSA determine that a sufficient supply of the required outer packagings is not available. They have determined there are currently a sufficient number of packaging manufacturers available to
supply the required outer packagings. Therefore, they are not extending the October 1, 2009 compliance date.
After September 30, 2009, cylinders of compressed oxygen and other oxidizing gases and packages of chemical oxygen generators must be placed in rigid outer packagings that meet the specified flame penetration and
thermal resistance requirements when transported aboard an aircraft and certain additional requirements.
A. For a cylinder containing compressed oxygen and other oxidizing gases intended for transportation by
aircraft, the following requirements apply:
1. The cylinder must be placed in a rigid outer packaging that is capable of passing, as demonstrated
................by design testing, the Flame Penetration Resistance Test in Appendix E to 49 CFR Part 178.
2. The cylinder and the outer packaging must be capable of passing, as demonstrated by design test................ing, the Thermal Resistance Test specified in Appendix D to 49 CFR Part 178.
3. The cylinder and the outer packaging must both be marked and labeled in accordance with Subparts
................D and E of 49 CFR Part 172. The additional marking, “DOT31FP” is allowed to indicate that the cylin................der and the outer packaging are capable of passing, as demonstrated by design testing, the Thermal
................Resistance Test.
4. Prior to each shipment, the package must be visually inspected to verify that all features of the pack................aging are in good condition, including all latches, hinges, seams, and other features, and that the
................packaging is free from perforations, cracks, dents, or other abrasions that may negatively affect the
................flame penetration resistance and thermal resistance characteristics of the packaging.
continued on Page 8
Page 8
Chemical Oxygen Generators
continued fron Page 7
5. A cylinder of compressed oxygen that has been
.........furnished by an aircraft operator to a passenger
.........in accordance with 14 CFR §§121.574,
.........125.219, or 135.91 is excepted from the outer
.........packaging requirements of paragraph (f)(3) of §
.........173.302.
B. For a chemical oxygen generator and a chemical
oxygen generator installed in equipment and
intended for transportation by cargo-only aircraft, the
following requirements apply:
1. The device must be placed in a rigid outer packaging that is capable of passing the Flame Penetration Resistance Test in Appendix E to 49 CFR Part
178 and the Thermal Resistance Test specified in
Appendix D to 49 CFR Part 178.
2. None of the following conditions may occur when
one generator in the package is actuated:
.........a. Actuation of other generators in the package;
.........b. Ignition of the packaging materials; and
.........c. A temperature above 100 °C (212 °F) on the
.............outside surface temperature of the package.
3. All features of the packaging must be in good
.........condition, including all latches, hinges, seams,
.........and other features, and the packaging must be
.........free from perforations, cracks, dents, or other
.........abrasions that may negatively affect the flame
.........penetration resistance and thermal resistance
.........characteristics of the packaging, verified by a
.........visual inspection of the package before each
.........shipment.
The full text of these regulations can be found on the
PHMSA website under “Regulations” at:
http://www.phmsa.dot.gov/staticfiles/PHMSA/Downloadable
Files/Files/Federal%20Register%20Historical%20Files/72fr_
_2007/72fr-4442.pdf
As President and
CEO of the Infotrac
Corporation, I would
like to thank all
our customers that
we have had the pleasure
to serve over the past year.
I only hope that Infotrac has
managed to make your HazMat
and MSDS requirements as well
as your first aid and spill release
issues, one less problem you had
to deal with in these hard
economic times.
As President, I will ensure
that Infotrac continues to be
the most dedicated and
professional response company
in North America.
I would like to wish each and
everyone in the Infotrac Family,
a very Happy Holiday Season
and a Very Prosperous New
Year.
Sincerely,
Anthony J. Kob Sr.