Re: DoT training req. for limited quantity carriers

[prattd@ccmail.orst.edu (David S. Pratt)]

     Les:
     
     Small quantities differ from limited quantities in that: a) 
     prototype testing of the package is required; b) hazmat employee 
     training is not required; and c) incident notification is not 
     required.
     
     Dave Pratt                                                        
     Senior Health Physicist    
     Radiation Center           
     Oregon State University
     100 Radiation Center
     Corvallis OR 97331-5903
     Phone: (541)737-7048
     FAX: (541)737-0480
     E-Mail:prattds@rc.orst.edu
     
     


______________________________ Reply Separator _________________________________
Subject: DoT training req. for limited quantity carriers
Author:  Lester.Slaback@nist.gov at Internet_Gateway
Date:    12/8/97 10:23 AM


To summarize comments received from my previous posting:
 - most stated that the DoT training requirement DID apply for persons who
would transport limited quantity packages.
 - one response (from an authoritative source) said no.
     
An unofficial conversation with a DoT rep confirmed the 'no'.
     
49CFR173.4(a)(1)(iv) exempts limited quantity shipments from this training 
requirement. 49CFR173.423(b)(3) specifically requires the training, but 
only if it is a multiple hazard shipment and the other hazard is not also 
subject to the 173.4 waiver.
     
Are there any other pertinent issues that I have overlooked?
Send responses to me and I will further summarize (if necessary).
     
-- 
the above are the personal musing of the author, 
and do not represent any past, current, or future
position of NIST, the U.S. Government, or anyone else
who might think that they are in a position of authority. 
NBSR Health Physics
NIST
Gaithersburg, MD 20899
301 975-5810
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Lester.Slaback@nist.gov
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