Q1. In order to satisfy the function specific training requirements of the HMR is it sufficient for training based on the ICAO TI to include the topics in subpart C of part 171 plus the reference to the U.S. State Variations published in the ICAO TI?. Or would all differences between 49 CFR and the ICAO TI regarding air transport need to be addressed?

A1. Training conducted to comply with the ICAO TI may be used to satisfy the function specific training requirements set forth in § 172.704 to the extent that such training addresses functions authorized by subpart C of part 171. Differences between the HMR and the ICAO TI that are not specifically addressed in subpart C of 171 or in U.S. State Variations in the ICAO TI are not required to be covered to comply with the requirements of § 172.704.

Q2. Is a person who receives training based on the ICAO TI, to include the topics in subpart C plus the reference to the State Variations published in the ICAO TI, required to know about combustible liquids?

A2. No. See A1 above. As combustible liquids are not mentioned by name or by reference in either subpart C of part 171 or in the U.S. State Variations of the ICAO TI, no training on this topic would be required.

Q3. Is a training certification completed in accordance with the ICAO TI requirements sufficient to provide proof of the function-specific training required by § 172.704(a)(2)? Or would a certification completed in accordance with the ICAO TI requirements need to have additional text entered giving reference to § 172.704?

A3. A record of training must be maintained for each hazmat employee under § 172.704(d). Certification of training is one element of this training record. Section 172.704(d)(3) requires a description, copy, or the location of the training materials used to meet the requirements in §172.704(a) to be a part of the hazmat employee's record. This requirement is similar to the requirement found in the ICAO TI. Regardless of the method chosen to comply with the requirement in § 172.704(d)(3), examination of information in the training record should indicate the training sufficiently addressed the areas required (e.g. function specific, subpart C of part 171, U.S. State Variations).