Interpretation Response #24-0026
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: North American Transportation Consultants, Inc.
Individual Name: John F. Christman
Location State: NJ Country: US
View the Interpretation Document
Response text:
September 24, 2024
John F. Christman
Certified Logistics Practitioner
North American Transportation Consultants, Inc.
P.O. Box 1404
Hightstown, NJ 08520
Reference No. 24-0026
Dear Mr. Christman:
This letter is in response to your April 15, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. Specifically, you ask whether the exceptions provided in § 172.704(e)(1) apply to manufacturing personnel such as welders and other employees who work on both hazmat and non-hazmat packagings.
The answer is yes. Personnel engaged in manufacturing of packagings used to transport hazardous materials in commerce, such as welders, are considered hazmat employees and subject to training. Specifically, they are subject to general awareness, function-specific, and security training as outlined in § 172.704(a)(1), (a)(2), and (a)(4). However, in accordance with § 172.704(e), for manufacturing personnel that are not handling or potentially exposed to hazmat during the course of performing their job functions, the safety training in § 172.704(a)(3) is not required. The required trainings may be provided by company training programs, consultative services (e.g., training firm colleges and universities, or Federal or State agencies), or through the completion of self-guided training.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.704(e)(1), (a)(2), and (a)(4), 172.704(a)(3), 172.704(e)
Regulation Sections
Section | Subject |
---|---|
172.704 | Training requirements |