Hazmat Training Records – What is the Burden?

The FAA is seeking comments on the burden associated with hazmat training records. This information will typically be shared with OMB, which manages recordkeeping obligations.

The FAA mandates that certificate holders, like airlines and repair station, must obtain hazmat training and they must retain records of such training. The FAA’s guidance suggests that repair station must create training manuals for their hazmat training obligation. E.g. FSIMS Vol. 6, Chap. 9, Sec. 2, Para. 6-1653(F). Repair stations are also required to obtain hazmat training and document that training.

The government periodically collects information on record-keeping obligations. This is an opportunity to file comments about the accuracy of their estimates on time consumed in record-keeping.

ASA filed comments challenging the current estimates, based on the proposition that hazmat recordkeeping typically takes more time than the estimates provide (mc0-o5c0-79jk).

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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