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Interpretation Response #08-0281 ([United Parcel Service] [Mr. Samuel S. Elkind])

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

Interpretation Response Details

Response Publish Date:

Company Name: United Parcel Service

Individual Name: Mr. Samuel S. Elkind

Location State: GA Country: US

View the Interpretation Document

Response text:

December 12, 2008

Mr. Samuel S. Elkind

Corporate Regulated Goods Manager

United Parcel Service

55 Glenlake Parkway, NE

Atlanta, GA 30328-3474

Ref. No. 08-0281

Dear Mr. Elkind:

This responds to your November 14, 2008 letter requesting clarification on training requirements under §172.704(d) in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the name and address of the person performing the training may be the company or corporate name and address, based on the definition of "person" in §171.8 of the HMR.

The answer is yes. It is the opinion of this office that the term "person" under §171.8 applies to the requirement in §172.704(d)(4). Therefore, the individual name and address of the person providing training or the name and address of the company or corporation providing the training may be used to satisfy the requirement in §172.704(d)(4).

I hope this answers your inquiry.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.704, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.704 Training requirements