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Interpretation Response #03-0234 ([Spokane Packaging] [Mr. Chris Ingram])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Spokane Packaging

Individual Name: Mr. Chris Ingram

Location State: WA Country: US

View the Interpretation Document

Response text:

May 19, 2004

 

Mr. Chris Ingram                Reference No. 03-0234
Spokane Packaging
3808 N. Sullivan Road
SIP Bldg #21
Spokane, WA 99216

Dear Mr. Ingram:

This responds to your letter regarding training under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask how your company may train one of your packaging designers to become “certified” to test UN Standard packagings.

The training requirements for hazmat employees, to -include those who certify UN Standard packagings as meeting the requirements of the HMR, are found in § 172.704. Hazmat employee training must include4 (1) general awareness/familiarization training; (2) function-specific training; (3) safety training; (4) security awareness training; and, if applicable, (5) in-depth security training.  A hazmat employee who tests packagings as qualified for use in the transportation of hazardous materials, and who does not perform any other function subject to the HMR, is excepted from the safety training requirements of 172.704(a)(3).

It is the responsibility of a hazmat employer to certify that a hazmat employee is trained and tested as required by the HMR.  The training of a hazmat employee may be accomplished in a number of different ways.  The Department does not, however, provide this training nor does it endorse any private, public, or commercial enterprise that does.  We suggest that you visit our Internet Website at http://hazmat.dot.gov/training.htm as a starting point for more information about the training requirements of the HMR.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.

Sincerely,

 

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

107.402

Regulation Sections