Interpretation Response #05-0064 ([Fibre Box Association] [Mr. Richard V. Soderberg])

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

Interpretation Response Details

Response Publish Date: 05/12/2005

Company Name: Fibre Box Association

Individual Name: Mr. Richard V. Soderberg

Location State: IL Country: US

View the Interpretation Document

Response text:

May 12, 2005

Mr. Richard V. Soderberg                      Reference No. 05-0064
Technical Manager
Fibre Box Association
2858 Golf Road
Rolling Meadows, IL 60008

Dear Mr. Soderberg:

This is in response to your March 18, 2005, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185). Specifically, you request clarification on the training requirements for the corrugated container manufacturing industry.

Your understanding is accurate, as the manufacturer of packagings used to transport hazardous materials in commerce, your hazmat employee training must include the provisions outlined in § 172.704(a)(1), (a)(2), and (a)(4). Your hazmat employee training is not required to include the provisions in § 172.704(a)(3), in accordance with § 172.704(e) or those provisions contained in § 172.704(a)(5), subject to applicability of security plan requirements under Part 172, Subpart I. The required training may be provided by company training programs, consultative services (e.g., training firm colleges and universities, or Federal or State agencies), or through the completion of self-guided training.

The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Hazardous Materials 1ni and Training offers at no charge a Security Awareness Training Module as an interactive CD-ROM designed to help hazmat employers comply with the security awareness training provisions in § 172.704(a)(4). The CD-ROM and many other training materials may be ordered by contacting the Office of Hazardous Materials Initiatives and Training at 202-366- 4900 or by accessing PHMSA’s Web site at the following URL: http://hazmat.dot.gov/

I hope this satisfies your request.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.704

Regulation Sections