Fibre Box Association — Hazardous Materials Safety Interpretation

Page 1J.S. Departmen of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety MAY 12 2005 Mr. Richard V. Soderberg Ref. No. 05-0064 Technical Manager 2858 Golf Road Fibre Box Association Rolling Meadows, IL 60008 Dear Mr. Soderberg: This is in response to your March 18, 2005, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185). Specifically, you request clarification on the training requirements for the corrugated container manufacturing industry. Your understanding is accurate, as the manufacturer of packagings used to transport hazardous materials in commerce, your hazmat employee training must include the provisions outlined in § 172.704(a)(1), (a)(2), and (a)(4). Your hazmat employee training is not required to include the provisions in § 172.704(a)(3), in accordance with § 172.704(e), or those provisions contained in § 172.704(a)(5), subject to applicability of security plan requirements under Part 172, Subpart I. The required training may be provided by company training programs, consultative services (e.g., training firmis, colleges and universities, or Federal or State agencies), or through the completion of self-guiderd training. The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Hazardous Materials Initiatives and Training offers at no charge a Security Awareness Training Module as an interactive: CD-ROM designed to help hazmat employers comply with the security awareness training provisions in § 172.704(a)(4). The CD-ROM and many other training materials may be ordered by contacting the Office of Hazardous Materials Initiatives and Training at 202-366- 4900 or by accessing PHMSA's Web site at the following URL: http://hazmat.dot.gov/ I hope this satisfies your request. Sincerely, John A. Gale Chief, Standards Development Office of Hazardous Materials Standards 172:704 050064#

Page 2Frcm from R. Soderberg to 12023663012 at 3/19/2005 1:51 PM 001/001 BAH $ 12:704 (raining 05-0064 Fibre Box Association 2850 Call Raw elling Means, I BE LS4 31350100 7M3F363 wwwwlitct=x.=0 March 18,2005 Mr. Feward Mazzulto Director. Oflice of Hazardous Malerials +007" St, S.W.. Room (OTMI!)) Washington, I2.C. 20590 Mr. Mazzullo this is an inquiry for clarilication of Tlaz Mat "Training Requirements" for the 49(:FR.172.704, item (a). parts (1) to (5) corrugated container manufacturing industry: Specitie paragraphs for reference are As we interpret this section, manufacturers of corrugated boxcs must fulfill the requirements of parts (1) and (2), but are not required to fulfill parts (3) and (5). Is that ассигне? The question then is this: "Are manuthcturers of corrugated boxes required to coinply with part (4). 'Security Awareness Training"? Il' your interpretation is that part (1) is required for corrugated box manufacturers, what kind ol'training is required, and where can the training matcrials be obtained? Thank: for your assistance in clarifying this matter. Very truly yours. Richard V. Soderberg Technical Manager, Fibro Box! Phone 847 364-4638 Fax 847 364-9639#