Guidanceguidance
02-0237
Remel Inc. Ramsey Division — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1.S. Departmen f Transportatior 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration NOV - 8 2002 Mr. Richard Sher Ref No.: 02-0237 Facility & Safety Supervisor Lemel Inc. Ramsey Divisio 4000 Unity Street NV Ramsey, MN 55303 Dear Mr. Sher This is in response to your September 13, 2002, letter concerning the training requirements for carriers and drivers transporting hazardous materials shipped under the small quantity exception in § 1.73.4 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Materials which meet the requirements of §1.73:4 are not subject to any other requirements of the subject to the formal training requirements of Subpart I in Part. 172 and Part 177. A person who HMR. Therefore, persons who ship hazardous materials under the provisions of § 173.4 are not offers small quantity shipments is responsible for properly classifying the material, determining that the material may be shipped as a small quantity and otherwise ensuring compliance with the provisions of § 173.4. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, Done 13lf0 Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.4 020237#
Page 2HLEAUN IKENU PAGE 82/82 14000 Unity Street NW Remel Inc. Ramsey Division Ramsey, MN 55303 September 13, 2002 § 173:40rd 173:4 Ed Mazzullo Director for the Office of Hazardous Materials Standards § 177.816 US DOT/RSPA (DHM)-20 Washington DC 20590-0001 400 7TH Street SW Diver Iraining/ Dear Sir: tiahwa 1Z-0237 interpretations of the mcaning of the first paragraph of 173.4; namely the phrase, "are not subject to I am writing this letter to try to get an official intexpretation of 49 CFR 173.4. I have heard different any other requirements of this subchapter" My question: does the exception apply to carries & drivers? Would a carrier or driver need to meet squirements of 49CFR 177.816 Driver, training? please clarify whether or not a driver would roquire a haz-mat endorsement on their CD ig goods classified under 173.4 small quantity exceptions? If the driver doc not require a ersement are there any requirements of the carrier when hauliag goods under 173.4? shand she acility & Safety Supervisor aid Sher Rsher@xemeliac.com Dircot Phone # 763-712-2322 Direct Fax # 763 712 -2366 ...... . . .#
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