Becton Dickinson Healthcare Systems — Hazardous Materials Safety Interpretation

Page 1173.22 of Transportation U.S. Department $400 Seventh Street, S.W. Washington, D.C. 20590 Research and MAY 2 4 1999 Special Programs Administration Mr. Mark Welch Ref- No. 299-0126 Becton Dickinson Healthcare Systems 1 Becton Drive Franklin Lakes, New Jersey 07417 Dear Mr. Mark Welch: This is in response to your letter dated May 11, 1999, requesting clarification on the training requirements under the Hazardous Materials Regulations (HMR, 49 CFR Parts 171-180) Specifically, you ask whether a shipper is responsible for verifying that a carrier or driver is qualified to transport hazardous materials. The answer is no. Each hazmat employer must certify that each of its hazmat employees has been trained and tested within 90 days of employment as required by $ 172,704 (c) and (d) The responsibility for providing training remains with each hazmat employer. The terms "hazmat employer" and 'hazmat employee" are defined in $ 171.8. 84 I hope this information is helpful. - If we can be of further assistance, please contact us. Sincerely, Holle I. Mitcke Hattie I. Mitchell, Chief Regulatory Review and Reinvention office of Hazardous Materials Standards 990126#

Page 2BettS $173.22 Becton Dickinson Healthcare Systems 99-0126 Franklin Lakes, New Jersey 07417 1 Becton Drive i (201) 847-6800 Ex 6954 /Fax 2018475350 BECTON DICKINSON Tuesday, May 11, 1999 Mr. Edward T. Mazzullo Director's Office Hazardous Materials US DOT/RSPA 400.74 St SW (DHM-10) Washington, DC 20590-0001 Dear Mr. Mazzullo, I am writing in hopes of getting a letter of interpretation on shippers/consignee responsibility or liability in verifying that a carrier and the individual driver is qualified to transport HazMats. Are we as a shipper responsible to check drivers picking up and. delivering Haz Mats for proper certification? Thank you in advance for your help. Respectfully, MarkWelkh Mark Welch#