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Interpretation Response #08-0078 ([Covance Laboratories, Inc.] [Ms. Dee Kaiser])

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

Interpretation Response Details

Response Publish Date:

Company Name: Covance Laboratories, Inc.

Individual Name: Ms. Dee Kaiser

Location State: WI Country: US

View the Interpretation Document

Response text:

May 23, 2008

Ms. Dee Kaiser

EHS Manager

U.S. Clinical Pharmacology

Covance Laboratories, Inc.

3301 Kinsman Boulevard

Madison, WI 53704

Reference No. 08-0078

Dear Ms. Kaiser:

This is in response to your March 20, 2008 e-mail and recent telephone conversations with a member of my staff asking if your company"s small network of extensively trained hazmat employees, herein described as "designated employees," may provide the company"s other hazmat employees with the training they need to prepare and offer for transport materials, and accommodate transport conditions, not covered in their initial training under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You also ask if it would satisfy the training requirement for the designated employee to provide the employee needing this information with the correct packaging instructions and a completed shipping paper with a signed shipper"s certification.

You state the employees needing this information are located at multiple clinic sites throughout the United States, and have received hazmat training that covers most conditions encountered when transporting exempt human specimens, exempt quantities of "UN 1845, Dry ice, 9 (miscellaneous), PG III," and "UN 3291, Regulated medical waste, n.o.s., 6.2 (infectious), PG II" by motor vehicle. You also state the designated employees may not be located at each of these sites, and the packages may need to be transported by aircraft.

Although self-training is acceptable and may be used, a packaging instruction and certified shipping paper are in themselves not "training" under the HMR and may not be sufficient to provide the knowledge level necessary to prepare a hazardous material package for transportation in accordance with the HMR. In addition, each hazmat employer must certify that each of its hazmat employees has been trained and tested, as required. No specific testing method or document is required. The requirements in Subpart H of Part 172 do not state that an employee must "pass" a test; however, a hazmat employee may only be certified in those areas in which the hazmat employee can successfully perform the assigned duties. A record of current training must be created and retained by each hazmat employer as specified in 49 CFR 172.704(d).

The purpose of the training requirements is to ensure that each hazmat employer trains each hazmat employee. There are no provisions or procedures under the training requirements for review or approval of training programs or certification of instructors. A hazmat employer must determine the most suitable method (e.g., hands-on demonstrations, online training, or interactive CD"s) and source of training for its employees.

I hope this satisfies your request.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.704 Training requirements