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Interpretation Response #03-0316 ([Bechtel Nevada] [Mr. Jim Przybylski])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bechtel Nevada

Individual Name: Mr. Jim Przybylski

Location State: NV Country: US

View the Interpretation Document

Response text:

Mar 9, 2005


Mr. Jim Przybylski                 Reference No. 03-0316
Bechtel Nevada
P.O. Box 98521
Las Vegas, NV 89193—8521

Dear Mr. Przybylski:

This responds to your letter requesting clarification of the training requirements under § 172.704 (a) (2) (i) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as related to Class 7 (radioactive) materials. I apologize for the delay in responding.  You state that, as authorized by § 171.11 of the HMR, your company ships Class 7 materials in compliance with the International Civil Aviation Organization’s Technical Instructions for the Safe Transportation of Dangerous Goods by Air (ICAO Technical Instructions), and the applicable State and operator Variations noted in the ICAO Technical Instructions and the International Air Transport Association’s Dangerous Goods Regulations. You were given written guidance that employees trained in accordance with the HMR are not required to be trained in accordance with the ICAO/IATA. You ask whether a hazmat employee who offers Class Ti materials for transportation is required to complete function--specific training only on the HMR requirements or must the training include function-specific training under the ICAO Technical Instructions, considering the HMR and ICAC) requirements are not identical, e.g., package marking and shipment documentation.

When hazardous materials are prepared in accordance with the ICAO Technical Instructions, as authorized by § 171.11 of the HMR, a hazmat employee may receive function-specific training based on the requirements of the ICAO Technical Instructions, as an alternative to the function-specific training required by the HMR. As specified in
§ 172.704 (a) (2) (ii), however, the training must address any additional functions and limitations identified in § 171.11, such s the requirements contained in § 171.11(d) (6). As you are probably aware, we revised the HMR requirements for transporting Class 7 materials based on changes contained in the International Atomic Energy Agency
Regulations for the Safe Transport of Radioactive Materials (TS-R-l (ST-i, Revised)). The requirements for transporting Class 7 materials contained in the HMR and the ICAO Technical Instructions are now more closely aligned.

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



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


Regulation Sections

Section Subject
172.704 Training requirements