{"operation":"document","citation":"06-0255","title":"Energy Solutions Federal Services — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-01-04","effective_on":null,"summary":"06-0255 response to Energy Solutions Federal Services concerning 172.704.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0255.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0255.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0255","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060255.pdf","body":"<<<PAGE 1>>>\n\nof Transportatior\nU.S. Department\nJAN -4 2007\nWashington, D.C. 20590\n401) Seventh Street, S.W.\nHazardous Materials Safety\nPipeline and\nAdministration\nTraffic Manager\nMr. James Portsmouth\nRef. No.: 06-0255\nEnergy Solutions Federal Services\n345 Hills Street\nRichland WA. 99354-5507\nDear Mr. Portsmouth:\nThis is in response to your October 26, 2006 letter requesting clarification of the\napplicability of training requirements provided in the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171- 180). Specifically, you ask whether the training requirements\ncontained in the HMR apply to employees who prepare shipments of hazardous waste for\nin accordance with Subpart H of Part 172.\ntransportation in commerce when those employees are overseen by a person fully trained\nThe answer is yes. Except as provided in § 172.704(c)(1), hazmat employees who\nperform regulated functions must be trained in the HMR requirements that apply to that\nfunction (172.702(b)). Regulated functions include: (1) determining the hazard class of a\nmaterial; (2) selecting an appropriate packaging; (3) filling a packaging; (4) securing\npackaging closures; (5) marking and labeling a package; and (6) preparing shipping\ntraining, and security awareness training in accordance with Subpart H of Part 172.\npapers. Hazmat employees must receive general awareness, function specific, safety\nTraining conducted to comply with requirements of the Occupational Safety and Health\nAdministration, the Environmental Protection Agency, or other mandated training\nrequirements may be used to the extent that such training satisfies the training and testing\nrequirements in Subpart H of Part 172.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\n172.704\nC60255\n\n<<<PAGE 2>>>\n\nLeary\n$172. TOH\nENERGYSOLUTIONS Training\nTi Duratek\nFederal Services\n\"Federal Services\n06-0255\nOctober 26, 2006\nJHP-07-4603\nOffice of Hazardous Materials Standards, PHH-1\nMr. Edward T. Mazzuillo, Director\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n700 7* Street S.W.\nAttention: DHM-10\nWashington, D.C. 20590-0001\nREQUEST FOR CLARIFICATION OF THE HAZARDOUS MATERIALS\nREGULATIONS\nDear Mr. Mazziullo:\nThe purpose of this letter is to request clarification of the Hazardous Materials\nthe requirement for employers to provide \"hazmat employees\" DOT training.\nRegulations (HMR:49 CFR Parts 171-180), and in particular 172.704(a) in regards to\nEnergySolutions Federal Services, Inc. formally known as Duratek Federal Services,\nresponsibility in tat toe rainford Stis facility, is to paching nuer pra ok and prepare\nesponsibility in the operations of this facility,\nand standar ast) oxes (sarBs) and over past shims as neded. These operarums s\nto, the OSHA 40-hour, 24-hour and 8-hour refresher which train these employees ir\nhave completed numerous DOE sponsored training classes to include but not 'imited\nfor transport. This training includes some basic Department of Transportation (DOT)\nhazardous materials general awareness and safety training.\nAdditionally, each group of operators is overseen by a Person in Charge (PIC) who\nhas had all of the required DOT training in 172.704. This PIC oversees the Operators\nin the actual loading of the SWBs and drums, as well as any over packing activities.\n509-376-7055 • Fax: 509-372-1435 • www.energysolutions.com\n345 Hills Street • Richland, Washington 99354-5507\n\n<<<PAGE 3>>>\n\nENERGYSOLUTIONS\nTi Durcitek\nFederal Services\nE Federal Services\nPlease address the following question:\nIf the PIC is fully trained in the DOT regulations in 49 CFR Subpart H and is\nthe drums and SWBs, does each individual involved in this process require the DOT\ndirecting the Operators in what to place in the containers and how to load and prepare\nplease feel free to contact me at (509) 376-7164 or by e mail at\nIf you need any additionally information regarding this request for interpretation,\nJHPortsmouth@energysolutions.com.\nSincerely,\ngames H1. briomouth\nJames H. Portsmouth\nTraffic Manager\nafs\n509-376-7055 • Fax: 509-372-1435 • www.energysolutions.com\n345 Hills Street • Richland, Washington 99354-5507","truncated":false,"body_characters":4189}