RE: 49 CFR/ICAO/IATA Training

[Wilson Robert H PSNS <wilsonr@PSNS.NAVY.MIL>]

This interpretation says that the shipper is not subject to the "carrier"

training requirements.  When this says "carrier" does that mean those

imposed by a individual carrier or those specific to a carrier?  What about

the other aspects of shipping such as the requirements for shipping papers,

marking, labeling, and packaging?  



-----Original Message-----

From: Roy A. Parker [mailto:royaparker@COMPUSERVE.COM]

Sent: Thursday, December 19, 2002 7:24 AM

To: William V Lipton; William G. Nabor

Cc: radsafe@list.vanderbilt.edu

Subject: 49 CFR/ICAO/IATA Training





The sentence in the 1997 interpretation is misleading when it says "the

shipper is not subject to the carrier training requirements."  I have not

gone back to the 1997 ICAO and IATA regulations, but the current ICAO/IATA

regulations explicitly state their training sections apply to shippers.



Albeit this still does distract from the fact that the 2 year period

specified in ICAO and IATA is not applicable, as stated below by Bill Lipton

and in my earlier e-mail reply.



Roy A. Parker, Ph.D.

roy@royparker.org

Tel: 225-924-1473

Fax: 225-924-4269



----- Original Message -----

From: "William V Lipton" <liptonw@dteenergy.com>

To: "William G. Nabor" <wgnabor@uci.edu>

Cc: <radsafe@list.vanderbilt.edu>

Sent: Wednesday, December 18, 2002 2:55 PM

Subject: Re:





>

> You do NOT need training every 2 years.  There is a DOT letter of

> interpretation available on the hazmat safety home page.  Look for the

> interpretations for 49 CFR 172.702.  It's a letter to John Nipper, dated

May 6,

> 1997.  It states:

>

> "A shipper who uses the ICAO Technical Instructions for the transport of

> hazardous materials, domestically or internationally, must be re-trained

at

> least once every three years in accordance with paragraph 172.704(c).

Although

> a shipper offers hazardous materials in accordance with the ICAO Technical

> Instuctions, as provided in paragraph 171.11, the shipper is not subject

to the

> carrier training requirements of the ICAO Technical Instructions."

>

> The opinions expressed are strictly mine.

> It's not about dose, it's about trust.

> Curies forever.

>

> Bill Lipton

> liptonw@dteenergy.com

>

> "William G. Nabor" wrote:

>

> > Dear Radsafers:

> >

> >     The U.S. DOT regulations require shippers of radioactive material to

be

> > retrained every 3 years.  IATA says every 2 years.  I have in my notes

from

> > Roy Parker's class that the U.S. adopted IATA, but cannot find chapter

and

> > verse.  Dr. Parker, are you out there?  I need to prove (by quoting some

> > regulation) that I need retraining every 2 years.  No credit given for

> > deducing why this is needed.  Or, if it's the case, why IATA's 2-year

> > requirement doesn't apply.  Can anybody help?  Thanks.

> > ---------------------

> > W. G. Nabor

> > Senior Health Physicist

> > University of CA, Irvine

> > WGNABOR@UCI.EDU





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