Interpretation Response #00-0100 ([Northrop Grumman] [Mr. David Norton])

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

Interpretation Response Details

Response Publish Date: 05/04/2000

Company Name: Northrop Grumman

Individual Name: Mr. David Norton

Location State: TX Country: US

View the Interpretation Document

Response text:

May 4, 2000

Mr. David Norton                Ref .No. 00-0100
Northrop Grumman
P.O. Box 655907 M/S 93-01
Dallas, Texas 75265-5907

Dear Mr, Norton:

This is in response to your letter dated March 29, 2000, requesting clarification on the training requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether persons certifying hazardous materials shipments by aircraft require training in the use of both the international Air Transport Association's (IATA) Dangerous Goods Regulations and the HMR.

Section 172.702 requires that a hazmat employer ensure that each of its hazmat employees is trained in accordance with the HMR.  Section 172.704(a)(2)(ii) provides that as an alternative to function-­specific training on the requirements of the HMR, training on the requirements of the International Civil Aviation Organization's Technical Instructions and the International Maritime Dangerous Goods Code may be provided if such training addresses the functions authorized by §s171.11 and 171,12 of the HMR.  Training may be provided by the hazmat employer or other public or private sources, including training classes that are offered by the IATA to the extent that the IATA training addresses the training specified in §172.704, in order to avoid unnecessary duplication of training.

I hope this answers your inquiry.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

172.704

Regulation Sections