Interpretation Response #01-0317 ([Mr. Joseph Cleveland])

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

Interpretation Response Details

Response Publish Date: 01/10/2002

Company Name:

Individual Name: Mr. Joseph Cleveland

Location State: NJ Country: US

View the Interpretation Document

Response text:

January 10, 2002

Mr. Joseph Cleveland                      Reference No. 01-0317
Hazardous Materials Advisory
    Council
203 Towne Centre Drive
Hillsborough, NJ 08844

Dear Mr. Cleveland:

This is in response to your November 13, 2001 letter conceming the training requirements in the Hazardous Materials Regulations (HRM;49 CFR Parts 171-180).  Specifically, you ask that we clarify the responsibility of the hazmat employer with regards to ftinction-specific training required in § 172.704 (a)(2) if part, but not all, of this requirement is met through a third party training program.

It is the responsibility of the hazmat employer to ensure and certify that each hazmat employee receives ftinction-specific training concerning requirements of this subehapter, which are specifically applicable to the functions the employee performs, in accordance with § 172.704 (a)(2).  This may be accomplished by any number of training methods, including the use of third-party training facilities.

Please note that this office neither reviews nor certifies training programs.  Each hazmat employer has its own unique operational requirements.  A hazmat employer must determine training needs of its hazmat employees based on the employer's requirements and each employee's specific job functions.

I hope this satisfies your request.

Sincerely,

Delmer F. Billings
Chief, Regulations Development
Office of  Hazardous Materials Standards

172.704

Regulation Sections