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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #05-0283 ([Transportation Development Group] [Mr. Jim Powell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Transportation Development Group

Individual Name: Mr. Jim Powell

Location State: CA Country: US

View the Interpretation Document

Response text:

Jul 3, 2006


Mr. Jim Powell                        Reference No. 05-0283
Transportation Development Group
2390 Crenshaw Blvd., Suite 513
Torrance, CA 90501

Dear Mr. Powell:

This responds to your November 5, 2005 letter requesting clarification on training requirements for shipping small quantities of hazardous materials under § § 171 .11 and 173.4 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180). Specifically, you request clarification on the applicability and frequency of training required under the HMR when shipping hazardous materials under § 171.11 using the excepted quantity provision in the International Civil Aviation Organization Technical Instructions (ICAO TI) for the Safe Transport of Dangerous Goods by Air.

Employees who prepare hazardous materials for transportation in accordance with the small quantity provisions of § 173.4 of the HMR are excepted from the training requirements in § 172.700-172.704. With respect to the training required by the ICAO TI, § 171.11 authorizes the use of the ICAO TI when the hazardous material is packaged, marked, labeled, and described and certified on a shipping paper and otherwise in condition for shipment as required by the ICAO TI. It is the shipment, not the shipper that has to meet all the conditions of the ICAO TI. As such, persons preparing and shipping hazardous materials under the provisions of § 171.11 using the ICAO TI excepted quantity provisions are subject only to the applicable training requirements of the HMR. In the case of an excepted quantity shipment fully conforming to the provisions of § 173.4 (including the marking required by § 173 .4(a)(10)), training would not be required. However, other competent authorities implementing the ICAO TI may require training for excepted quantity shipments.

I hope this answers your inquiry.



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

171.11, 72.704, 173.4(a)(10)

Regulation Sections

Section Subject
173.4 Small quantities for highway and rail