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Interpretation Response #19-0069

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

Interpretation Response Details

Response Publish Date:

Company Name: HQ U.S. Army Europe Safety (AECS-S)

Individual Name: Mr.Donald Paglioni

Location City: Wiesbaden Country: DE

View the Interpretation Document

Response text:

August 15, 2019

Mr. Donald V. Paglioni
Deputy Safety Director
HQ U.S. Army Europe Safety (AECS-S)
Unit 29352 Box 108
APO AE  09014

Reference No. 19-0069

Dear Mr. Paglioni:

This letter is in response to your May 29, 2019, emailed memorandum, and July 31, 2019, email and phone call with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training.  Specifically, you ask whether the HMR permits a German-licensed United States (U.S.) Army Schoolhouse to teach a European Hazardous Material Driver Course to U.S. Army personnel on military installations in the continental U.S. (CONUS), and to issue European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) driver’s licenses upon successful completion of this course.

This Office does not review or certify training programs.  However, as the Competent Authority for the U.S. within the U.S. Department of Transportation for purposes of the HMR, we hereby inform you that our Office does not have any objections against ADR Dangerous Goods Driver Training (Hazardous Material Driver Training Course HAZ 11), as authorized and certified by the German Federal Ministry of Defense, being provided to members of the U.S. Army in the territory of the U.S.  The provisions of the HMR apply to the transportation of a hazardous material in commerce and each person who offers and/or transports a hazardous material in commerce in the jurisdiction of the U.S. (see § 171.1(c) and the definition of "commerce" in § 171.8).  The ADR applies to dangerous goods transported internationally in road vehicles among European countries that agree by contract to comply with its provisions; thus, the ADR is not subject to the HMR.

I hope this information is helpful.  Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

cc: Mr. Michael B. Schwarz
Director, Safety Office
Headquarters, United States Army Europe
Command Dangerous Goods Advisor
Lucius D. Clay Kaserne
65205 Wiesbaden
GERMANY

171.1(c), 171.8

Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions
171.8 Definitions and abbreviations