North American Transportation Consultants, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 September 24, 2024 John F. Christman Certified Logistics Practitioner North American Transportation Consultants, Inc. P.O. Box 1404 Hightstown, NJ 08520 Reference No. 24-0026 Dear Mr. Christman: This letter is in response to your April 15, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. Specifically, you ask whether the exceptions provided in § 172.704(e)(1) apply to manufacturing personnel such as welders and other employees who work on both hazmat and non-hazmat packagings. The answer is yes. Personnel engaged in manufacturing of packagings used to transport hazardous materials in commerce, such as welders, are considered hazmat employees and subject to training. Specifically, they are subject to general awareness, function-specific, and security training as outlined in § 172.704(a)(1), (a)(2), and (a)(4). However, in accordance with § 172.704(e), for manufacturing personnel that are not handling or potentially exposed to hazmat during the course of performing their job functions, the safety training in § 172.704(a)(3) is not required. The required trainings may be provided by company training programs, consultative services (e.g., training firm colleges and universities, or Federal or State agencies), or through the completion of self-guided training. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Cardez 24-0026 From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Request for Interpretation Date: Friday, April 19, 2024 9:38:01 AM Attachments: Request for Clarification.pdf Importance: High Hi Alice, Please see the attached interpretation request. Let me know if you need anything. Regards, -Breanna From: John Christman <jchristman@natc-inc.com> Sent: Monday, April 15, 2024 10:08 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: John Christman <jchristman@natc-inc.com>; JP Gibbons <jpgibbons@natc-inc.com> Subject: Request for Interpretation Importance: High 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. Please see my request attached. I would appreciate a return email to let me know my request has been received. Thank You, John F. Christman Certified Logistics Practitioner jchristman@natc-inc.com Phone (609)426-0555#

Page 3Fax (609)443-0004 NATC www.49cfr.com#

Page 4April 15, 2024 Office of Pipeline Safety (PHP-30) U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. S.E. Washington, DC 20590-0001 To whom it may concern: I would like to request an official Request for Clarification from PHMSA on the following under Section 172.704 (e): Does 49 CFR 172.704 (e) include new manufacturing personnel such as welders and others who work on both HazMat and non-HazMat packaging or just the engineers who design the packaging and those who are responsible for inspecting and certifying the package for HAZARDOUS Material transportation under 49 CFR? Please email your response to JChristman@natc-inc.com Regards, John F. Christman, Certified Logistics Practitioner North American Transportation Consultants, Inc. P.O. Box 1404 Hightstown, NJ 08520 jchristman@natc-inc.com Phone – (585) 313-1637 Fax - (609) 443-0004#