Landstar System, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration APR 1 5 2003 Mr. David Saporito Landstar Director, Hazardous Materials Ref. No. 03-0068 13410 Sutton Park Drive South System, Inc. Jacksonville, FL 32224 Dear Mr. Saporito: clarification of the training This responds to your March 6, 2003 letter requesting Materials Regulations (HMR; 49 CFR Parts 171-180) • requirements under the Hazardous you ask if $ 172.704 (d) (4) requires the training record to Specifically, training or the company that employs the trainer. contain the name and address of the individual providing the Under § 172.704 (d) (4), the training record must contain the name provided training. and address of the person (i.e., his/her business address) that are one in the same then that address must be maintained within If the trainer's home and business address the training record. I hope this satisfies your request. Sincerely John A. Gale Transportation Regulations Specialist Office of Hazardous Materials Standards.. 030068 172.704#

Page 203/07/2003 14:43 FAX @002/002 LANASTAR' BAH Landstar sysion. inc. 13410 Sutton Pod Diva Bowi 8172.704464 Jocksonwie, FL 32224 904 398 9400 raining Edward Mazzullo Director, Hazardous Materials Standards March 6, 2003 0 3-0068 USDOT/RSPA (DHM10) 400 7* St. SW Washington, DC 20590-0001 Mr. Mazzullo, I would like to request clarification from your department regarding hazardous material training certificate requirements. I have received differing opinions from the RSPA Hotline and need to assure compliance for our certificates. Specifically I need clarification regarding 49CFR § 172.704 (4)(d)(4), for the address of person providing the training. Should this address be the company's address where the record keeping is maintained or the the personal address of the trainer or the address where the training address of the actual trainer? Taking it a step further, would it be is provided? If the personal address of the trainer is required would the statement "On file in Human Resources" be acceptable so that the person would not have to list their home address? As I stated earlier I have received conflicting interpretations regarding what address to use and..What would be acceptable should the personal address be required. Thank you in advance for your prompt response to this inquiry. A fax response can be made to 888-345-9220 or mailed to the address listed above. Sincerely, Dail Sapott David Saporito Director, Hazardous Materials#