A STOCK CLERK RPTS CARRIER'S HAZMAT TRAINING COURSE FAILED TO CLARIFY PROPER INCIDENT AND DISCREPANCY RPTING PROCS.

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CONTRARY TO 14 CODE OF FEDERAL REGS AND 49 CODE OF FEDERAL REGS; A RECENT ACR X HAZMAT TRAINING COURSE (AND; AS I RECALL; ALL PREVIOUS COURSES AND TESTS) FAILED TO CLARIFY PROPER INCIDENT AND DISCREPANCY RPTING PROCS. THIS ISSUE HAS BEEN BROUGHT TO THE ATTN OF THE COMPANY VIA A 58 PAGE RPT OF IRREGULARITY I FILED IN 1998; BUT TO THIS DAY THE COMPANY'S HAZMAT TRAINING COURSES FAIL TO INFORM HAZMAT EMPLOYEES OF THE EMPLOYEE'S -- OR PERSON'S -- RPTING RESPONSIBILITIES (EG; SEE 14 CODE OF FEDERAL REGS 13.1 AND 49 CODE OF FEDERAL REGS 171.31; ETC) VERSUS THE CARRIER'S RPTING RESPONSIBILITIES (EG; SEE 49 CODE OF FEDERAL REGS 171.15; 171.16; ETC). THOUGH THE DEFINITIONS -- OR LACK OF DEFINITIONS -- IN 14 CODE OF FEDERAL REGS AND 49 CODE OF FEDERAL REGS OF TERMS SUCH AS AIR CARRIER; CARRIER; PERSON; HAZMAT EMPLOYEE; AND HAZMAT EMPLOYER ARE AMBIGUOUS; CONFUSING; CONFLICTING; AND OPEN FOR DEBATE; THE INTENT OF THE RPTING PROCS OF THE FAR'S AND HMR'S ARE CLR -- THESE REGS WERE CREATED AS A SYS OF CHKS AND BALS; A SYS THAT WOULD ENSURE ALL HAZMAT INCIDENTS AND DISCREPANCIES WERE RPTED TO THE APPROPRIATE FEDERAL AGENCY(IES) CONSISTENTLY AND UNBIASEDLY. HOWEVER; HAZMAT EMPLOYERS LIKE ACR X CLRLY FAIL TO ACKNOWLEDGE AND INFORM HAZMAT EMPLOYEES OF THE DISTINCTION BTWN THESE 2 ENTITIES AND THEIR 2 DISTINCT RPTING RESPONSIBILITIES. ON SEVERAL OCCASIONS OVER THE LAST FEW YRS; I HAVE SPOKEN WITH SEVERAL FAA OFFICIALS CONCERNING THESE ISSUES; AND ONE OF THESE INDIVIDUALS; AFTER CONSULTING WITH ONE OF THE DEPT'S ATTORNEYS; STATED SIMPLY BECAUSE A HAZMAT EMPLOYEE OR PERSON NOTIFIED THEIR IMMEDIATE SUPVR OF AN ILLEGAL SHIPMENT OF HAZMAT ON AN ACFT; THAT HAZMAT EMPLOYEE WAS IN NO WAY RELIEVED OF ANY RESPONSIBILITIES OR LIABILITIES THESE FEDERAL REGS CREATED (AS NOTED IN THE 1998 RPT OF IRREGULARITY). STILL; THOUGH WE; THE HAZMAT EMPLOYEES; CAN STILL BE HELD RESPONSIBLE FOR THESE INCIDENTS AND DISCREPANCIES; WE; THE HAZMAT EMPLOYEES (IE; THE INDIVIDUALS THAT DISCOVER ILLEGALLY SHIPPED HAZMAT); HAVE NO WAY OF KNOWING OR DOCUMENTING WHETHER OUR EMPLOYER'S HAVE; IN FACT; NOTIFIED THE APPROPRIATE FEDERAL AGENCY(IES) OF THESE HAZMAT INCIDENTS AND DISCREPANCIES; SINCE; IN FACT; THE FAR'S AND HMR'S DO NOT REQUIRE THE HAZMAT EMPLOYERS TO PROVIDE THE RPTING HAZMAT EMPLOYEES DOCUMENTATION THAT THE HAZMAT EMPLOYERS HAD; IN FACT; NOTIFIED THE APPROPRIATE FEDERAL AGENCY(IES).