Interpretation Response #02-0050
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
May 31, 2002
Mr. William K. Taggart, CET Reference No.: 02-0050
Lion Technology, Inc.
P. 0. Drawer 700
Lafayette, New Jersey 07848
Dear Mr. Taggart:
This is in response to your letter regarding §§ 172.704 and 171204(d) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if an individual who signs the shipper's certification required under § 172.204(a) must be trained in all phases of hazmat transportation.
Your understanding is correct. The training requirements apply to hazmat employees who perform any function subject to the requirements of the HMR (§ 172.704(b)); this includes an employee who signs a shipping paper certification. Since the employee certifies that the materials are properly classified, described, packaged, marked and labeled and in proper condition for shipment, the employee must receive function specific-training that ensures they are knowledgeable in those areas and can determine that a shipment is in compliance with the requirements of the HMR, in addition to general awareness/familiarization and safety training.
I hope this satisfies your request.
John A. Gale
Transportation Regulations Specialist
office Hazardous Materials Standards
|§ 172.704||Training requirements|