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Interpretation Response #08-0180 ([Parcels Plus] [Mr. Bruce Bernstein])

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

Interpretation Response Details

Response Publish Date:

Company Name: Parcels Plus

Individual Name: Mr. Bruce Bernstein

Location State: FL Country: US

View the Interpretation Document

Response text:

October 6, 2008

Mr. Bruce Bernstein

Parcels Plus

2637 E Atlantic Boulevard

Pompano Beach, FL 33062

Ref. No.: 08-0180

Dear Mr. Bernstein:

This is in response to your July 10, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding training. Your scenario is based on a Mail and Parcel Center (MPC) that neither accepts nor offers hazardous material shipments for transportation in commerce. Your questions are paraphrased and answered below.

Q1. Are employees of the MPC described above required to be trained in accordance with Subpart H of Part 172?

A1. No. The hazardous materials training requirements in Subpart H of Part 172 of the HMR establishes training requirements for hazardous materials employees (hazmat employees). A hazmat employee is a person who, in the course of his employment, directly affects hazardous materials transportation safety (see § 171.8).

Q2. If training is not required for the employees of the MPC, how would DOT view the MPC, as a shipper, if the employees receive training in accordance with Subpart H of Part 172?

A2. As long as the MPC does not transport or offer hazardous materials for transportation in commerce, the DOT would view the MPC as a shipper of non-regulated materials who is not subject to the provisions of the HMR.

Although the HMR do not require your employees to be trained, you may wish to consider providing your employees with guidance or training to assist them to identify a package that may contain hazardous materials so that they do not inadvertently accept such a package for transportation.

You should also be aware that the Federal Aviation Administration has issued regulations governing air carriers that do not accept or transport hazardous materials, and these regulations may apply to some aspects of an MPC"s operation. You may wish to contact

Mr. Christopher Bonanti, Director, Office of Hazardous Materials, ADG-1,

Federal Aviation Administration, 800 Independence Ave, SW, Room 300 East,

Washington, DC 20591, 202-267-9864, for additional information.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.704, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.704 Training requirements