Aristech Chemical Corporation — Hazardous Materials Safety Interpretation

Page 1.. = of Transportation U.S.Department Washington, D.C. 400 Seventh Street, S.W. . 20590 Research and Special Programs Administration MAR 2 4 1999 Mr. Michael D. Alston Logistics Specialist - Hazardous Materials Rei. No. 98-0338 Aristech Chemical Corporation 600 Grant Street, Room 1020 Pittsburgh, PA 15219 Dear Mr. Alston: This is in response to your letter dated November 3, 1998 regarding S$ 172:704 and 172.204 (d) of the Hazardous Materials Regulations wish to verity that the training requirements apply to an (HMR; 49 CFR Parts 171-180): Specifically. you individual who signs the shipper!s certification required under $ 172.204(a). Your underständing is correct. The training requirements apply to hazmat employees who perform functions that are subject to the requirements of the HMR (S. 172.702 (b)); this includes the employee who signs the shipping paper certification. I hope this satisfies your request. Sincerely, Transportation Regulations specialist Office of Hazardous Materials Standards 172.704#

Page 2600 Grant Street Aristech Chemical Corporation Pitsburgh. PA 15219-2704 ARISTECH H SP.ta4 November 3, 1998 98-0338 Associate Administrator for Hazardous Materials Safety Attention: Standards,DHM-10 Research and Special Programs Administration U.S. Department of Transportation 400 7" Street, SW Washington, DC 20590-0001 : Dear Sir(s), Hazardous Materials Regulations. I am writing this letter to request an interpretation of a regulation contained in CFR Title 49- The section 172.204 d Shipper's Certification - Signature: states that the certifications required by paragraphs (a) and (c) of this section: (1) Must be legibly signed by a principal, officer, 'pärtner or employee of the shipper or his agent. Do the persons. stated in section 172:204 d. (1) need to receive training in General Awareness, Function Specific and Safety training as required by 172704?.. " 1a.;. i Your response to this request would be appreciated. Recently, I was informed by a former. Department of Transportation Inspector that the persons in question did. not need training according to section 172.704, however, I firmly believe this to be incorrect. You may respond to: Aristech Chemical Corporation Michael D. Alston Logistics Specialist-Hazardous Materials S00 Grant Street, Room -1020 412-433-7948 Pittsburgh, PA 15219 412-433-7544 (Fax) • Sincerely, litter • Michael D. Alston • Logistics Specialist-Hazardous Materials CC: P.C. Rine E.H. Weber Aristech Total Performance ЛАТР#