PHMSA 2015 HMIT Grant for Hazmat Employee Training

PHMSA response: Yes. Application materials may be sent electronically on a readable CD or thumb drive.

PHMSA Response: Yes. Even though the initial period of performance is 6 months, in the application please provide a budget, with activities and milestones for an entire year.

PHMSA Response: No.

Question Received from an Applicant: The curriculum file is extremely large and can’t be attached to the electronic application.

PHMSA Response: If the training curriculum is too large to send electronically, PHMSA will accept the curriculum via mail. Applicants should indicate in their application that the curriculum will be sent separately via mail due to size.

The package should be addressed to Lisa ODonnell at the following address:
US Department of Transportation
Pipeline and Hazardous Materials Safety Administration
Hazmat Grants Program/ PHH-50
East Bldg, 2nd Floor E-23-301
1200 New Jersey Avenue, SE
Washington, DC 20590.

Question Received from an Applicant: The Assurance of Compliance with Title VI of the Civil Rights Act has sections that we are unsure of how to complete?

PHMSA Response: You do not need to sign anything except for the basic assurance document on page 3. On page 2, under Specific Assurances, item 3 discusses the appendices A-E and asks the recipient (you) to insert the appropriate clauses in the appendices in to every contract or agreement you enact using the funds from the grant. Items B, C and D apply only if PHMSA gives your organization land or money to build a facility then these must be part of any contracts or agreements passing the land or money on to other entities.

PHMSA Answer:
No. The Funding Opportunity Announcement should have included all entities that meet the definition of a hazmat employee under 49 CFR Section 171.8, which includes a person employed by a department, agency, or instrumentality of the United States Government, or an authority of a State, political subdivision of a State, or an Indian tribe; and who: (i) Transports hazardous materials in commerce; (ii) Causes hazardous materials to be transported in commerce; or (iii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package, container, or packaging component that is represented, marked, certified, or sold by that person as qualified for use in transporting hazardous materials in commerce.

PHMSA Answer:
The HMIT grant is open to non-profit organizations. OMB A-122 defines non-profits as follows:

(A)ny corporation, trust, association, cooperative, or other organization which:

(1) is operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest;

(2) is not organized primarily for profit; and

(3) uses its net proceeds to maintain, improve, and/or expand its operations. For this purpose, the term non-profit organization excludes (i) colleges and universities; (ii) hospitals; (iii) State, local, and federally recognized Indian tribal governments; and (iv) those non-profit organizations which are excluded from coverage of this Circular in accordance with paragraph 5.

Organizations who meet this definition, in addition to other eligibility criteria, will be deemed eligible applicants for the HMIT grant.

PHMSA Answer:
PHMSA understands such information may be difficult to obtain for some applicants. However, it is important to understand this information plays a vital role in establishing deficiencies used to forecast training needs. Further, its inclusion gives the grant application strength which can potentially result in a higher ranking than if not. Applicants are highly encouraged to conduct needs assessments to determine the areas where hazmat training is needed. Applicants are also encouraged to read the priority letter included in the Funding Opportunity Announcement to better understand PHMSA’s training priorities.

PHMSA Answer:
At this time there is no set rate for F&A. If the applicant has F&A negotiated in an indirect cost agreement, we recommend using that rate. Please note, if an applicant projects to make indirect charges to the grant, the current negotiated indirect cost agreement must be included in the grant application package.

Please clarify the language underlined below:

Projects funded under this grant award must demonstrate that the recipient organization 1) has the ability to reach and offer train the trainer trainings that will result in the training of all hazmat employees in a specific industry, geographic area or target population, i.e, chemical industry employees, motor carrier employees, railroad employees, air carrier employees; 2) the organization(s) or geographic area targeted for training have not received hazmat training comparable to the one being offered in the last three years; and 3) the organization(s) or proposed geographic area targeted for training has no existing trainers that could provide the training being proposed, or it has insufficient numbers of skilled trainers to train the number of individuals that need to be trained.

PHMSA Answer:
Projects funded under this grant must demonstrate that the training will be conducted in a location where there is a need for training and the risk for hazmat incidents is high.

Applicant Question: As discussed at our site visit and per the super circular 200.414 and 200.415 for our indirect cost rate, we “may elect to charge a de minimis rate of 10% of the modified total direct costs…” Our question is how this should be addressed/requested in the application. Would attaching the following statement where an indirect cost rate proposal would go work. Per the super circular CFR 200.414 and 200.415, a de minimis indirect cost rate of 10% of the modified total direct costs will be charged.

PHMSA Response: applicants should list the requested indirect costs in the 424A budget, as well as the budget narrative, based on the 10% calculation. In the budget narrative, the applicant should confirm that they are eligible, and state that they are requesting the de minimis rate of 10% per 2 CFR 200.414. List the total amount of indirect costs requested, as well as the amount of the base that was used to calculate the indirect costs.

Per the regulation, the 10% rate is to be based upon Modified Total Direct Costs (MTDC), which is described at 200.68 as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and subawards and subcontracts up to the first $25,000 of each subaward or subcontract. MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward and subcontract in excess of $25,000.

1. Applicant Questions:

a) I entered the web site from the instructions to test the adobe acrobat. I did not get the application package or the directions to get the latest adobe software but received the message
The requested resource was not found. http://www.grants.gov/assets/ADOBE-VERSIONING-TEST-ONLY

PHMSA Response: To verify if you have a compatible version of Adobe Reader installed, click on the following link and follow the directions: http://www.grants.gov/web/grants/support/technical-support/troubleshooting/verifying-adobe-reader.html

b) What dates should we enter for the start and end date (box 17)?

PHMSA Response: On SF 424 form; box 17, PHMSA suggests for the applicant to enter the following: Proposed Project a. Start Date: 04/01/2015 b. End Date; 09/30/2015, (with written requests from authorized representatives, PHMSA will extend the period of performance until 03/31/2016.)

“Areas that will not be funded under this grant award include but are not limited to: generic software training unless the applicant can demonstrate the hazmat employee’s place of employment utilizes this application in their hazmat safety processes.”

PHMSA RESPONSE:
Training provided with HMIT grant funds must be a systematic program that ensures a hazmat employee has familiarity with the general provisions of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180), is able to recognize and identify hazardous materials, has knowledge of specific requirements of the HMR applicable to functions performed by the employee, and has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures. (See 49 CFR §172.700(b).)

The HMIT grant program office will allow training on software applications that are comparable to the software applications that trainers will use as an aid in training hazmat employees in the HMR. As with all Federal grant expenditures, the cost of the software application training must be allocable, allowable and reasonable.

¿Areas that will not be funded under this grant award include but are not limited to: generic software training unless the applicant can demonstrate the hazmat employee¿s place of employment utilizes this application in their hazmat safety processes.¿

PHMSA RESPONSE:
Training provided with HMIT grant funds must be a systematic program that ensures a hazmat employee has familiarity with the general provisions of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180), is able to recognize and identify hazardous materials, has knowledge of specific requirements of the HMR applicable to functions performed by the employee, and has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures. (See 49 CFR §172.700(b).)

The HMIT grant program office will allow training on software applications that are comparable to the software applications that trainers will use as an aid in training hazmat employees in the HMR. As with all Federal grant expenditures, the cost of the software application training must be allocable, allowable and reasonable.