Interpretation Response #98-0428
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Date: JUL 16 1998 Reply to Attn. of:
Subject: ACTION: Clarification of Training Requierements
From: Edward T. Mazzullo, Director,
RSPA Office of Hazardous Materials Standards
To: Charles Lovinski, Manager,
HAZMAT and Dangerous Goods Program
This is in response to your memo requesting clarification of employee (or contractor employee) training requirements. Your question is paraphrased and answered as follows:
Question: Are employees of (or contractor employees for) an airline who perform security functions related to cargo, including loading and unloading onto pallets and xray machines, opening for inspection, and transporting cargo that includes hazmat to the aircraft, required by the Hazardous Materials Regulations (HMR) to have function-specific training?
The answer to your question is yes. Both employees and contract employees of an airline who perform any function subject to the requirements of the HMR are required to be instructed in the requirements of the HMR that apply to those functions. Section 172.704 contains the requirements for the training of hazmat employees, one item of which is function-specific training (§ 172.704 (a) (2». We also believe that this answer is consistent with the training requirements of the International Civil Aviation Organization's (ICAO) Technical Instructions.
I trust this satisfies your inquiry. If this office can be of further assistance, please contact us.
|§ 172.704||Training requirements|