Training for Shipments by Aircraft

This is in response to your letter dated March 29, 2000, requesting clarification on the training requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether persons certifying hazardous materials shipments by aircraft require training in the use of both the international Air Transport Association's (IATA) Dangerous Goods Regulations and the HMR.

Section 172.702 requires that a hazmat employer ensure that each of its hazmat employees is trained in accordance with the HMR. Section 172.704(a)(2)(ii) provides that as an alternative to function-specific training on the requirements of the HMR, training on the requirements of the International Civil Aviation Organization's Technical Instructions and the International Maritime Dangerous Goods Code may be provided if such training addresses the functions authorized by §§ 171.11 and 171.12 of the HMR. Training may be provided by the hazmat employer or other public or private sources, including training classes that are offered by the IATA to the extent that the IATA training addresses the training specified in § 172.704, in order to avoid unnecessary duplication of training.

I hope this answers your inquiry.