Baker Hughes — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 NOV - 1 1999 Ms. Shelley A. Espinoza Ref. No. 99-0204 Baker Hughes Post Office Box 1407 Houston, Texas 77251-1407 Dear Ms. Espinoza: This is in response to your letter dated July 16, 1999, regarding the definition of a "hazmat employee" in 49 CFR 171.8 as it applies to an individual performing evaluation of documentation accompanying a cylinder assembly under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The employee is not involved in the manufacturing process, assembly, testing, marking, packaging or transportation of the cylinders. Based on the information provided in your letter, when an employee of your company is responsible for evaluating documentation accompanying a cylinder assembly (assembly is inspected and verified by an independent inspection agency prior to the evaluation) to determine if the components of the assembly meet the quality and design standards authorized for transportation under a DOT exemption, such an employee is a "hazmat employee," as defined in 49 CFR 171.8. Each "hazmat employee" who performs a function subject to the exemption must receive training on the requirements and conditions of the exemption in addition to the training required by 49 CFR 172.700 through 172.704. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Helme Hilling Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 990204 111.8#

Page 2Apola, 3W1D 120 Emplozel BAKER HUGHES 99-0201 Baker Atlas P.O. Box 1407 Houston, Texas 77251-1407 Tel 713-972-4000 July 16, 1999 Mr. Delmer F. Billings Chief, Standards Developmen Office of Hazardous Materials Standards JS Dept. of Transportation/RSPA 400 Seventh Street, SW Washington, DC 20590 Dear Mr. Billings: Baker Atlas is seeking a RSPA interpretation regarding the definition of a "hazmat employee" in 49 CFR 171.8. Specifically, we are asking if an individual performing the function described below is considered a "hazmat employee". assembly meet the quality and design standards established by Baker Atlas. The cylinder assembly is authorized Function: Evaluate documentation accompanying a cylinder assembly to determine if the components of the for transport under a DOT exemption. Before this evaluation is conducted, the assembly is inspected and verified by an independent inspection agency as required in 49 CFR 178.35(c). Individuals performing the evaluation function are not involved in the manufacturing process, assembly, testing, marking, packaging or transportation of the cylinders. Your assistance in this matter is greatly appreciated. Please advise if additional information is needed. Regards, Kelly Aspirag HISE Advisor Shelley A. Espinoza cc: Pat Boles Mike Gourley HEALTH, SAFETY, AND ENVIRONMENT DEPARTMENT # (713-)972-4411 FAX (713) 972-5752#