Interpretation Response #02-0214 ([CTC Certified Training Co.] [Darrell Garton])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: CTC Certified Training Co.
Individual Name: Darrell Garton
Location State: CO Country: US
View the Interpretation Document
Response text:
Dec 17, 2002
Mr. Darrell Garton Reference No. 02-0214
CTC Certified Training Co.
62537 North Star Dr.
Montrose, CO 81401
Dear Mr. Garton:
This is in response to your August 13, 2002 letter concerning training requirements under the Hazardous Materials Requirements (HMR; 49 CFR Parts 171,480). Specifically, you ask if an Independent Inspection Agency(IIA) can remain "independent" after it has performed one of the training requirements that are the responsibility of its client and objectively continue being an IIA to that entity.
Section 172,702(a) specifies that the hazmat employer, as defined in § 171.8, is required to ensure that each of its hazmat employees are trained in accordance with the requirement prescribed in subpart H of part 172. There are no requirement in this subpart for persons that provide training or specifics on training programs. Thus, an IIA could also be a trainer.
The IIA conflict-of-interest prohibition in § 107.803(b) only applies to control by, or a financial involvement with, a cylinder manufacturer-not cylinder requalifiers.
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief Standards Development
Office of Hazardous Materials Standards
172.702
Regulation Sections
| Section | Subject |
|---|---|
| 172.702 | Applicability and responsibility for training and testing |