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Interpretation Response #98-0428 ([HAZMAT and Dangerous Goods Program] [Charles Lovinski])

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

Interpretation Response Details

Response Publish Date:

Company Name: HAZMAT and Dangerous Goods Program

Individual Name: Charles Lovinski

Country: US

View the Interpretation Document

Response text:

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.


Regulation Sections

Section Subject
172.704 Training requirements