Computer Sciences Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration JUN 6 2006 Mr. James R. 'Hank' Ellis Ref. No. 06-0110 Director, Civil Engineer Vance Infrastructure Support Computer Sciences Corporation 140 Channel Street, Suite 201 Vance AFB OK 73705-5621 Dear Mr. Ellis: This responds to your April 21, 2006 letter requesting clarification on the applicability of the training requirements in Part 172 of the Hazardous Materials Regulations (HMR; 49 Specifically, you ask if the training requirements apply to an individual who signs the CFR Parts 171-180) to your hazardous waste generator certification signatory. shipper's certification required under § 172.204(a). The answer is yes. The training requirements apply to hazardous materials employees who perform functions that are subject to the requirements of the HMR (§ 172.702(b)); this includes the employee who signs the shipping paper certification. I hope this answers your inquiry. Sincerely, John A. Gale Chief, Standards Development Office of Hazardous Materials Standards 172.204(a) 060110#

Page 2Vance Infrastructure Support Computer Sciences Corporation Boothe 5172.205 April 21, 2006 Shipping Papers Edward Mazzulla U.S. Department of Transportation 06-0110 Pipeline and Hazardous materials Safety Administration Office of Hazardous Materials Safety 400 7 th Street Southwest Washington, D.C. 20590 Dear Mr. Mazzulla: CSC I am requesting an applicability determination for the manifesting requirements of 49 CFR for our situation here at Vance AFB Our hazardous waste disposal is contracted through a Defense Reutilization and Marketing Office contract via an external transporter. We do not utilize ary DOT transportation on Vance AFB, nor do we ever move HAZMAT on public roads. In our situation, do the manifest training rules of 49 CFR, Part 172 apply to the generator carries the manifest to the signature authority, and the transporter who prepares the certification signatory? More specifically, our certified hazardous waste manager hand manifest for generator certification is fully DOT trained Your quick response is greatly appreciated. If you have any questions, please contact Mr. Shannon Elledge at (580) 213-6226. Sincerely, lames R. 'Hank' Ellis Director, Civil Engineer JE/pt cc: File Vance AFB OK 73705-5621 140 Channel Street, Suite 201 (580) 213-7771#