{"operation":"document","citation":"24-0026","title":"North American Transportation Consultants, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2024-09-24","effective_on":null,"summary":"24-0026 response to North American Transportation Consultants, Inc. concerning 172.704.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0026.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0026.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0026","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-10/240026.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSeptember 24, 2024\nJohn F. Christman\nCertified Logistics Practitioner\nNorth American Transportation Consultants, Inc.\nP.O. Box 1404\nHightstown, NJ 08520\nReference No. 24-0026\nDear Mr. Christman:\nThis letter is in response to your April 15, 2024, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements.\nSpecifically, you ask whether the exceptions provided in § 172.704(e)(1) apply to manufacturing\npersonnel such as welders and other employees who work on both hazmat and non-hazmat\npackagings.\nThe answer is yes. Personnel engaged in manufacturing of packagings used to transport\nhazardous materials in commerce, such as welders, are considered hazmat employees and subject\nto training. Specifically, they are subject to general awareness, function-specific, and security\ntraining as outlined in § 172.704(a)(1), (a)(2), and (a)(4). However, in accordance with\n§ 172.704(e), for manufacturing personnel that are not handling or potentially exposed to hazmat\nduring the course of performing their job functions, the safety training in § 172.704(a)(3) is not\nrequired. The required trainings may be provided by company training programs, consultative\nservices (e.g., training firm colleges and universities, or Federal or State agencies), or through\nthe completion of self-guided training.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<>>\n\nCardez\n24-0026\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Request for Interpretation\nDate: Friday, April 19, 2024 9:38:01 AM\nAttachments: Request for Clarification.pdf\nImportance: High\nHi Alice,\nPlease see the attached interpretation request.\nLet me know if you need anything.\nRegards,\n-Breanna\nFrom: John Christman \nSent: Monday, April 15, 2024 10:08 AM\nTo: INFOCNTR (PHMSA) \nCc: John Christman ; JP Gibbons \nSubject: Request for Interpretation\nImportance: High\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nPlease see my request attached.\nI would appreciate a return email to let me know my request has been\nreceived.\nThank You,\nJohn F. Christman\nCertified Logistics Practitioner\njchristman@natc-inc.com\nPhone (609)426-0555\n\n<<>>\n\nFax (609)443-0004\nNATC\nwww.49cfr.com\n\n<<>>\n\nApril 15, 2024\nOffice of Pipeline Safety (PHP-30)\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave. S.E.\nWashington, DC 20590-0001\nTo whom it may concern:\nI would like to request an official Request for Clarification from PHMSA on the following\nunder Section 172.704 (e):\nDoes 49 CFR 172.704 (e) include new manufacturing personnel such as welders and\nothers who work on both HazMat and non-HazMat packaging or just the engineers who\ndesign the packaging and those who are responsible for inspecting and certifying the package\nfor HAZARDOUS Material transportation under 49 CFR?\nPlease email your response to JChristman@natc-inc.com\nRegards,\nJohn F. Christman,\nCertified Logistics Practitioner\nNorth American Transportation\nConsultants, Inc.\nP.O. Box 1404\nHightstown, NJ 08520\njchristman@natc-inc.com\nPhone – (585) 313-1637\nFax - (609) 443-0004","truncated":false,"body_characters":3702}