WMG Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration September 28, 2023 1200 New Jersey Avenue, SE Washington, DC 20590 Mr. John Grinley WMG Inc. 5391 Lakewood Ranch Blvd Suite 302 Sarasota FL 34240 Reference No. 23-0057 Dear Mr. Grinley: This letter is in response to your June 6, 2023, email and a subsequent phone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. Specifically, you ask whether training on the software used to generate hazardous materials shipping papers must be provided to a hazardous materials (hazmat) employee in accordance with the “Function-specific” training requirements specified in § 172.704(a)(2). The answer is yes. Function-specific training is required for the function(s) for which a hazmat employee is responsible. Therefore, if a hazmat employee must use a specific software to perform functions pertaining to the requirements of the HMR - such as classifying materials or generating hazardous materials shipping papers – the hazmat employee must be trained on that software. 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 2Wolcott From: INFOCNTR (PHMSA) To: Hazmat Interps Subject: FW: Clarification of Training Requirements Date: Tuesday, June 27, 2023 11:30:12 AM 23-0057 Hello, Please below request for interpretation. Thanks, Jonathon From: John Grinley <jgrinley@wmginc.com> Sent: Tuesday, June 6, 2023 11:49 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: J. Michael Reeves <jmreeves@wmginc.com> Subject: Clarification of Training Requirements 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. When a shipper uses a software program to characterize radioactive material and/or waste and to also generate paperwork associated with these shipments, I believe that training on the use of this software is required according to 49 CFR 172.704(a)(2) “Function-specific training”, as stated, "that are specifically applicable to the functions the employee performs" and the RADMAN software is a cornerstone of many nuclear power plants radioactive waste/material shipping programs. Using the software is a specific function to creating the documentation needed to ship this material/waste to a licensed facility for use, processing and/or disposal. Can you please confirm I am correct in my interpretation of this regulation. Best Regards, John Grinley Training & Customer Service Manager WMG, Inc. 5391 Lakewood Ranch Blvd, Suite 302 | Sarasota | Florida | 34240 Main: 914.736.7100 (New York Office) Desk: 914.370.8592 (Florida Office) Cell: 813.707.3080 (Florida) Email: jgrinley@wmginc.com | Website: www.wmginc.com#

Page 3Service…Innovation…Value…Integrity The information contained in this e-mail, including any attachments, contains confidential and proprietary information of WMG, Inc. which may be subject to disclosure restrictions under agreements between WMG and the intended recipient. The information is intended to be for the confidential use of the recipient(s) named above. If you are not the intended recipient, or an agent responsible for delivering to the intended recipient, be aware that any review, disclosure, copying, distribution or use of the contents of this e-mail is strictly prohibited. If you have received this e-mail in error, please notify the sender immediately and destroy all electronic and hard copies of the communication, including attachments.#