Total Technic — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration July 25, 2023 Mr. Hüseyin Demir Maintenance Engineer Total Technic Ataturk International Airport 34149 Istanbul, Turkey Reference No. 22-0116 Dear Mr. Demir: This letter is in response to your October 27, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. We have paraphrased and answered your questions as follows: Q1. You ask whether revisions to a special permit used by your employees necessitates an updated training of your hazmat employees. A1. Section 172.704(a)(2) requires that each hazmat employee must be provided function- specific training concerning requirements of the HMR—or exemptions or special permits issued under subchapter A—that are specifically applicable to the functions the employee performs. As such, if the Pipeline and Hazardous Materials Safety Administration adopts a new regulation, changes an existing regulation, or revises a special permit that relates to a function performed by a hazmat employee, the employee must be instructed on those changes as needed. While it is not necessary to completely retrain the hazmat employee sooner than the required three-year cycle, the employee must receive the instruction necessary to ensure this person is knowledgeable about the new or revised regulatory requirement including changes to applicable special permits. Q2. In your email, you describe a scenario in which one of your hazmat employees (Employee #1) conducts the training for all other hazmat employees (Employees #2-10) in your company. You ask whether Employee #1 may self-train or must be trained by another person.#

Page 2A2. Employee #1 may self-train, provided the general awareness/familiarization training, function specific training, safety training, security awareness training, in-depth security training, testing, recordkeeping, and certification requirements specified in § 172.704 are met. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3Pollack From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Subject: FW: DOT-SP TRAININGS Date: Thursday, October 27, 2022 12:53:22 PM Attachments: image001.png image006.png 22-0116 Hi Alice, Please see the below interpretation request. Let me know if you need anything else. Regards, -Breanna From: Hüseyin Demir <huseyin.demir@totaltechnic.aero> Sent: Thursday, October 27, 2022 9:29 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>; INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: Engineering Department <engineering@totaltechnic.aero> Subject: RE: DOT-SP TRAININGS CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Dear responsible, accordance with 49 CFR 105.20, I added infocntr@dot.gov, in mail list. To clear my question, I write it below again. How is DOT-SP revision change trainings is mandatory. I mean, when there is a DOT-SP revision changed. Is it compulsory to train HAZMAT Employees every time. The second question is. We have a trainer Mr. Sadık. He is an also HAZMAT Employee, he works as Certifying staff in Oxygen Workshop. As far as I am informed. He can train other employees. But Is it compulsory for him to be trained by third person. And is it compulsory to be every time. According to your web page: https://www.phmsa.dot.gov/standards- rulemaking/hazmat/hazardous-materials-information-center There is a information saying “To request a formal letter of interpretation or to mail your question, write to: Mr. Shane Kelley” So how can I forward this e-mail/question to him? There is not any specific e-mail account for him.#

Page 4Saygılarımla/Best regards, Hüseyin DEMİR Maintenance Engineer SHGM TR.145.086 | EASA.145.0530 | FAA Part 145 No 6TVY457C Ataturk International Airport, 34149 Istanbul, Turkey Ph: +90 (212) 465 28 65 (ext:1145) | Fx: +90 (212) 663 00 11 Mb:+90 (544) 835 97 10 www.total-technic.com huseyin.demir@totaltechnic.aero From: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Sent: Wednesday, October 26, 2022 10:09 PM To: Hüseyin Demir <huseyin.demir@totaltechnic.aero> Subject: RE: DOT-SP TRAININGS Dear Hüseyin, Attached is the document that you requested. Additionally, you can access the Code of Federal Regulations at www.ecfr.gov. I hope that this information is helpful. You may contact the Hazardous Materials Information Center, which is staffed with regulatory specialists who can quickly answer your questions by phone, Monday through Friday, 9 AM - 5 PM EST ator +1 (202) 366-4488. Sincerely, Breanna Hazardous Materials Information Center An e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance with 49 CFR 105.20. https://www.phmsa.dot.gov/standards- rulemaking/hazmat/hazardous-materials-information-center From: training (PHMSA) <training@dot.gov> Sent: Wednesday, October 26, 2022 9:07 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>#

Page 5Subject: FW: DOT-SP TRAININGS Hi Info center, Can you please assist Hüseyin? Thanks, Peter Heitzmann Communications US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE, Washington, DC, 20590 Mobile: 202.366.4425 PHMSA Home | LinkedIn | Twitter | HAZMAT | OHMS From: Hüseyin Demir <huseyin.demir@totaltechnic.aero> Sent: Thursday, October 20, 2022 5:57 AM To: training (PHMSA) <training@dot.gov> Cc: 'engineering@total-technic.com' <engineering@total-technic.com> Subject: DOT-SP TRAININGS CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Dear responsible; We are an aviation company with requilifier identification number (RIN: 1514) We have an issue about DOT-SP Revisions. How is DOT-SP revision change trainings is mandatory. I mean, when there is a DOT-SP revision changed. Is it compulsory to train HAZMAT Employees every time. The second question is. We have a trainer Mr. Sadık. He is an also HAZMAT Employee, he works as Certifying staff in Oxygen Workshop. As far as I am informed. He can train other employees. But Is it compulsory for him to be trained by third person. And is it compulsory to be every time. Saygılarımla/Best regards, Hüseyin DEMİR Maintenance Engineer#

Page 6SHGM TR.145.086 | EASA.145.0530 | FAA Part 145 No 6TVY457C Ataturk International Airport, 34149 Istanbul, Turkey Ph: +90 (212) 465 28 65 (ext:1145) | Fx: +90 (212) 663 00 11 Mb:+90 (544) 835 97 10 www.total-technic.com huseyin.demir@totaltechnic.aero#