Interpretation Response #14-0104
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
October 22, 2014
Mr. Richard J. Walsh
Trident Safety Group, House Unit 5
Westpoint Trade Centre
Link Road, Ballincollig
Co. Cork, Ireland
Ref. No. 14-0104
Dear Mr. Walsh:
This responds to your May 16, 2014, request for clarification on the training requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You request clarification on training requirements for United States (U.S.) companies shipping from Ireland into the U.S. by vessel and aircraft that already have completed International Civil Aviation Organization (ICAO) Technical Instructions and International Maritime Dangerous Goods (IMDG) Code training. Specifically, you request clarification on whether HMR training is required in addition to the ICAO and IMDG modal training.
HMR training requirements apply to persons who perform a covered function for hazardous materials transported in commerce to, from and within the U.S. The training must include general awareness, function-specific, safety, and security awareness training as specified in § 172.704(a) of the HMR. Training conducted to comply with the ICAO Technical Instructions or the IMDG Code may be used to satisfy the training requirements set forth in § 172.704 (see § 172.704(a)(2)(ii) and also § 171.22(g)(2)) to the extent that such training addresses the training components specified in § 172.704(a). Where this training does not satisfy the HMR, the employer or self-employed person must provide additional training to employees performing covered functions to comply with the HMR.
I hope this answers your inquiry. If you need additional assistance, please call this office at 202-366-8553.
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
172.704(a), 172.704(a)(2)(ii), 171.22(g)(2), 172.704(a)
|§ 171.22||Authorization and conditions for the use of international standards and regulations|