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Interpretation Response #10-0041 ([Britt & Brown LLP] [Mr. Andrew Brought])

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

Interpretation Response Details

Response Publish Date:

Company Name: Britt & Brown LLP

Individual Name: Mr. Andrew Brought

Location State: MO Country: US

View the Interpretation Document

Response text:

June 23, 2010





Mr. Andrew Brought

Britt & Brown LLP

1000 Walnut Street, Suite 1400

Kansas City, Missouri 64106-2140

Ref. No. 10-0041

Dear Mr. Brought:

This responds to your February 12, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the applicability of the HMR to Repair Stations certified by the FAA pursuant to 14 CFR Part 145 and the employees, who in the course of their repair operations may handle and temporarily store hazardous material cargo.

As specified in § 171.1, the HMR govern the safe transportation of hazardous materials in intrastate, interstate and foreign commerce. Generally, a "hazmat employee" is any person who is employed on a full-time, part-time, or temporary basis and who in the course of such employment directly affects hazardous materials safety. (See § 171.8 for the complete definitions of "hazmat employee" and "hazmat employer."). In other words, a person who performs duties that are regulated under the HMR is considered to be a hazmat employee. Part 175 contains requirements specifically applicable to the transportation of hazardous materials by aircraft. Any person who is responsible for performing a duty that is regulated by Part 175 is considered to be a hazmat employee. All hazmat employees must be trained in accordance with the requirements in Subpart H of Part 172 of the HMR.

Specific questions pertaining to the functions performed by FAA certified Repair Stations, including repairs of commercial and non-commercial aircraft containing hazardous cargo should be directed to FAA"s Office of Chief Counsel, Rebecca MacPherson, AGC-200.

I hope this information is helpful. If you have further questions, please contact this office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

171.1, 171.8, Subpart H of Part 172

Regulation Sections

Section Subject
171.8 Definitions and abbreviations