{"operation":"document","citation":"14-0104","title":"Trident Safety Group — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-10-22","effective_on":null,"summary":"14-0104 response to Trident Safety Group concerning 171.22, 172.704.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0104.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0104.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0104","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140104.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nOCT 2 2 2014\nMr. Richard J. Walsh\nManaging Director\nTrident Safety Group, House Unit 5\nWestpoint Trade Centre\nLink Road, Ballincollig\nCo. Cork, Ireland\nRef. No. 14-0104\nDear Mr. Walsh:\nThis responds to your May 16, 2014, request for clarification on the training requirements\nunaer tne Hazardous MaterialsReguiations (HMR -;- 4~-eFR - P:ms - 1/- 1-1 8\"0):\"\" You-nrquest\nclarification on training requirements for United States (U.S.) companies shipping from\nIreland into the U.S. by vessel and aircraft that already have completed International Civil\nAviation Organization (ICAO) Technical Instructions and International Maritime Dangerous\nGoods (IMDG) Code training. Specifically, you request clarification on whether HMR\ntraining is required in addition to the ICAO and IMDG modal training.\nHMR training requirements apply to persons who perform a covered function for hazardous\nmaterials transported in commerce to, from and within the U.S. The training must include\ngeneral awareness, function-specific, safety, and security awareness training as specified in\n§ 172.704(a) of the HMR. Training conducted to comply with the ICAO Technical\nInstructions or the IMDG Code may be used to satisfy the training requirements set forth in\n§ 172.7 04 (see § 172.7 04( a )(2 )(ii) and also § 1 71.22(g)(2)) to the extent that such training\naddresses the training components specified in§ 172.704(a). Where this training does not\nsatisfy the HMR, the employer or self-employed person must provide additional training to\nemployees performing covered functions to comply with the HMR.\nI hope this answers your inquiry. 202-366-8553.\nIf you need additional assistance, please call this office at\nSi . nc~ ,r ly , _, ~;; · · ?iJ. ··~ · .\n// z · . ~\n-\n:'' / . . . l . fr'\"'Z.-9'\n/ ~ ·~·\n;Dirk r K' · Cleren\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n/ 0 (II;·\n~\n~\nBoothe\n~ 17.Z~ 700\nTRIDENT\nSAFETY GROUP\n~11/,?~\nU.S. DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001. May 16th, 2014. Telephone\nRE: - Hazmat Training for organisations shipping into US Territories.\n--- I\n1 vatntY>Y1\nJ q- ()I ~Lp\nHead Office\nTrident House\nI\nUnit 5\nW estpoint Trade Centre\nLink Road\nI\nBallincollig\nCo. Cork\nIreland\n+353 21 487 9326\nFacsimile\n+353 21 48 7 9327\nEmail\nsales@tridentsafety.com\nWeb\nDear Madam/Sir,\nI am writing to your department to seek formal clarification in regards to the interpretatio o'f'ww.tridentsafety.com\nrammg requirements fC>TRazmat employees oftermg gooasfor t ranspo rt lnfOOSterrirories\ngoverned by Federal Regulation 49-CFR.\nBy way of introduction, our company is a training and consulting business operating in Ireland since\n1990. We offer hazmat training and deep knowledge support to international companies operating\nin Ireland and Europe in the wider sense. We have recognised courses for Road, Sea and Air (ADR,\nIMDG,ICAO)\nAs part of our expansion in training we hoped to offer 49-CFR training in Ireland /EU and we had\npartnered with a US based well recognised training organisation to facilitate the training of\ndelegates in Ireland as to the complexities of 49-CFR.\nOur query relates to the training requirements of 49-CFR and State Variation USG-01 from the ICAO\nTechnical Instructions Doc.9284/AN .905 .\nMany of our clients would have received ADR, ICAO and IMDG training previously.\nWe attempted to run a 49-CFR training course specifically aimed at US companies shipping from\nIreland into the US via Sea and Air transport modes and the feedback we received was that; \"49-CFR\ntraining is not required at any level as we have done ICAO and IMDG already.\"\nSo to frame our question; in light of the above, is 49-CFR training required additionally to the above\nmodal training?\nI welcome your response to this query at your earliest convenience.\nYours s-incerely,\nRichard J . W~Ish. Managing Director.\nRE}ift@e4!~1 a ld, t81JG!iel; P. V. Walsh\nTrident Industrial Safety Limited.\nCompany Registration No: 162327","truncated":false,"body_characters":4197}