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Interpretation Response #00-0281 ([Oshkosh Truck Corporation] [Mr. James T. Van Sistine])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Oshkosh Truck Corporation

Individual Name: Mr. James T. Van Sistine

Location State: WI Country: US

View the Interpretation Document

Response text:

November 7, 2000


Mr. James T. Van Sistine                Ref. No. 00-0281
Director, Defense Programs
Oshkosh Truck Corporation
P.O. Box 2566
Oshkosh, WI 54903-2566

Dear Mr. Van Sistine:

This is in response to your September 29, 2000, letter regarding the training requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you request clarification on whether all your employees would require DOT


A hazmat employee is a person employed by a hazmat employer and who in the course of employment directly affects hazardous materials transportation safety (see § 171.8). In other words, a person who performs duties that are regulated under the HMR is considered to be a hazmat employee.  Section 172.704 requires a hazmat employee to receive general awareness, function specific, and safety training.  Under § 172.704(e ), a hazmat employee who repairs, modifies, reconditions, or tests packagings as qualified for use in the transportation of hazardous materials, and who does not perform any other function subject to the HMR, is not subject to the safety training requirement of § 172.704(a)(3).

An employee who performs functions subject to the HMR, such as manufacturing and testing DOT specification cargo tanks is a hazmat employee.  Any employee who performs a function covered by the HMR, e.g., manufactures and tests packagings as qualified for use in the transportation of hazardous materials, is a hazmat employee and therefore must be trained.

I hope this satisfies your request.

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials  Standards


Regulation Sections

Section Subject
172.704 Training requirements