Ms. Dorothea A. Welk — Hazardous Materials Safety Interpretation

Page 1J.S. Department f Transportation 400 Seventh Street, S.W. NOV 7 2006 Washington, D.C. 20590 Hazing us Materials Satery Administration Ms. Dorothea A. Welk 31600 - 126"* St., S.E., #99 Ref. No. 06-0237 Auburn, WA 98092 Dear Ms. Welk: This is in response to your July 17, 2006 letter regarding training certification requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether an instructor or consultant must be "certified" under the HMR. Subpart H of Part 172 for review and approval of training programs or certificat on of The answer is no. There are no provisions or procedures under the training requirements in instructors. I hope this information is helpful. Sincerely, Chief, Standards Developmen Office of Hazardous Materials Standards 171.12a 060237 172.700#

Page 2Foster July 17, 2006 §171.12a $172.700 2006 JUL 24 P 2 52 Training 06-0231 PHMSA Chief Council 400 Seventh Street SW Room 8417 Washington, DC 20590 Dear Chief Council, I am questioning the certification of Dangerous Goods instructors and consultants. I could not find anything in 49 CFR that dealt specifically with the qualifications of either of these positions. I was informed that if the instructor or consultant does not perform any Dangerous Goods Functions such as creating a carrier bill or a Dangerous Goods Shipper's declaration, etc. that there is no requirement that they become 49 CFR, IATA, etc. certified in order to teach a DG class or consult on DG questions. I would just like to confirm that this is correct. Thank you, Allarsehen Q. Will 31600 - 126" ST. S.E, #99 Dorothea A. Welk Phone: 253-833-4532 Auburn, WA 98092#