{"operation":"document","citation":"98-0428","title":"HAZMAT and Dangerous Goods Program — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-07-16","effective_on":null,"summary":"98-0428 response to HAZMAT and Dangerous Goods Program concerning 172.704.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0428.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0428.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0428","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980428.pdf","body":"<<<PAGE 1>>>\n\nMemorandum\nU.S. Department\nof Transportation\nResearch and\nSpecial Programs\nAdministration\nDate:\nJUL 1 6 1998\nReply to Attn. of:\nSubject:\nFrom:\nRSPA Office of Hazardous Materials Standards\n*:\nCharles Lovinski, Manager,\nHAZMAT and Dangerous Goods Program\nThis is in response to your memo requesting clarification of employee (or contractor\nemployee) training requirements. Your question is paraphrased and answered as follows:\nQuestion: Are employees of (or contractor employees for) an airline who perform\nsecurity functions related to cargo, including loading and unloading onto pallets and x-\nray machines, opening for inspection, and transporting cargo that includes hazmat to\nthe aircraft, required by the Hazardous Materials Regulations (HMR) to have function-\nspecific training?\nThe answer to your question is yes. Both employees and contract employees of an airline\nwho perform any function subject to the requirements of the HMR are required to be\ninstructed in the requirements of the HMR that apply to those functions. Section 172.704\ncontains the requirements for the training of hazmat employees, one item of which is\nfunction-specific training (§ 172.704 (a) (2)). We also believe that this answer is consistent\nwith the training requirements of the International Civil Aviation Organization's (ICAO)\nTechnical Instructions.\nI trust this satisfies your inquiry. If this office can be of further assistance, please contact us.\ni..\n#\n:\n•\n\n<<<PAGE 2>>>\n\n*APE 6.1998\n3: 44PM\nCIVIL AVIATION SECURITY\nNO. 609\nP.2/2\nMemorandum\nof Transportation\nU.S. Department\nEdmorsion\nFederal Aviation\nFle: 172:704\nAdministration\nSubjecti\nACTION: Dangerous Goods Training for Air\nDate:\nCarrier Employees\nAPR - 6 1998\nFrom: Manager, Dangerous Goods & Cargo Security\nReply to\nAttn, ofi\nTo: Director, Office of Hazardous Materials Standards\n1\nThe Division Manager in our Southern region, has asked for an interpretation for the\nfollowing questions to the Hazardous Materials Regulations.\nAre employees (or contractor employees) for an airline who perform security functions\nrelated to cargo required to have function specific training?\nTheir duties include loading, unloading cargo onto pallets and x-ray machines, opening\ncargo for physical inspection, and transporting cargo to the aircraft. The aforementioned\ncargo does include hazardous materials.\nThe ICAO Technical Instructions, Part 6, page 6-1-1 and page 6-1-2 details the\ninternational community's standards and expectations relative to the kind of training\nrequired of certain employees.\nShould this ICAO requirements be taken into\n-\nconsideration when answering the above questions?\nwwilky\nfor Charles Lovinski","truncated":false,"body_characters":2674}