Interpretation Response #13-0056 ([UPS] [Mr. Matthew Maslanka])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: UPS
Individual Name: Mr. Matthew Maslanka
Location State: NJ Country: US
View the Interpretation Document
Response text:
April 5, 2013
Mr. Matthew Maslanka
Division Manager
UPS
2100 Center Square Road. Suite 400
Logan Township, NJ 08085
Ref. No.: 13-0056
Dear Mr. Maslanka:
This is in response to your March 4, 2013 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements.
In the scenario you provide, the shipper prepares small quantity packages in accordance with
§ 173.4. Your company then collects the packages and returns them to your terminal where the packages are sorted, weighed and routed via domestic ground transportation. Specifically, you ask whether employees handling a product that meets the small quantity requirements of
§ 173.4 are subject to the training requirements of Subpart H in Part 172.
The answer to your question is no. Materials which meet the requirements of § 173.4 are not subject to any other requirements of the HMR. Therefore, persons who handle shipments of hazardous materials under the provisions of § 173.4 are not subject to the formal training requirements of Subpart H in Part 172, unless they perform other hazardous materials transportation functions.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
173.4
Regulation Sections
| Section | Subject |
|---|---|
| 173.4 | Small quantities for highway and rail |