Northrop Grumman — Hazardous Materials Safety Interpretation

Page 1U.S.Department of Transportation Research and Special Programs Administration MAY 4 2000 Mr. David Norton Ref. No. 00-0100 Northrop Grumman P.O. Box 655907 M/S 93-01 Dallas, Texas 75265-5907 Dear Mr. Norton: This is in response to your letter dated March 29, 2000, requesting clarification on the training requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether persons certifying hazardous materials shipments by aircraft require training in the use of both the International Air Transport Association's (IATA) Dangerous Goods Regulations and the HMR. Section 172.702 requires that a hazmat 'employer ensure that each of its hazmat employees is trained in accordance with the HMR. Section 172.704(a)(2)(ii) provides that as an alternative to function- specific training on the requirements of the HMR, training on the requirements of the International Civil Aviation Organization's Technical Instructions and the International Maritime Dangerous Goods Code may be provided if such training addresses the functions authorized by §§ 171.11 and 171.12 of the HMR. Training may be provided by the hazmat employer or other public or private sources, including training classes that are offered by the IATA to the extent that the IATA training addresses the training specified in § 172.704, in order to avoid unnecessary duplication of training. I hope this answers your inquiry. Sincerely, Ohan Hillio Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 000100#

Page 2Boothe 3172.704 Aerostructures 00 - 0100 NORTHROP GRUMMAN stegrated system Northrop Grumman Corporation nd Aerostructures Secto Dallas, TX 75265-5907 Post Office Box 655907 C-82333/0L-013 29 March 2000 U.S. Department of Transportation Office of Hazardous Materials Standards 400 Seventh St. S.W. Washington, D.C 20590 Dear Sir, If a company prepares dangerous goods using both IATA (air shipments) and CFR 49 (domestic surface shipments), must the person who provides the hazardous material instructions (classification, packaging, marking, and labeling/placarding, etc.) and who signs the certification have formal training in both IATA and CFR 49? Or, is only having IATA training considered sufficient with the provision that the person must also have a strong working knowledge of CFR 49 requirements? Sincerely, DadaMate David Norton Northrop Grumman P.O. Box 655907 M/S 93-01 Dallas, Ix. 75265 PH. 972-946-3319 Fax. 972-946-3116 * Recycled Paper#