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Interpretation Response #99-0126 ([Becton Dickinson Healthcare Systems] [Mr. Mark Welch])

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

Interpretation Response Details

Response Publish Date:

Company Name: Becton Dickinson Healthcare Systems

Individual Name: Mr. Mark Welch

Location State: NJ Country: US

View the Interpretation Document

Response text:

May 24,1999


Mr. Mark Welch                                  Ref. No. 99-0126
Becton Dickinson Healthcare Systems
1 Becton Drive
Franklin Lakes, New Jersey 07417

Dear Mr. Mark Welch:

This is in response to your letter date May 11,1999, requesting clarification on the training requirements the Hazardous Materials   Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a shipper is responsible for verifying that a carrier or driver is qualified to transport hazardous materials.

The answer is no. Each hazmat employer must certify that each its hazmat employees have been trained and tested within 90 days of employment as required by 172.704(c) and (d). The responsibility for   providing training remains with each hazmat employer. The terms “hazmat employer” and “hazmat employee” are defined in 171.8.

I hope this information is helpful. If we can be of further assistance, please contact us.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility