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Interpretation Response #03-0048 ([Environmental Rernediation Systems, Inc.] [Mr. Danny R. Hubbard II])

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

Interpretation Response Details

Response Publish Date:

Company Name: Environmental Rernediation Systems, Inc.

Individual Name: Mr. Danny R. Hubbard II

Location State: LA Country: US

View the Interpretation Document

Response text:

May 21, 2003


Mr. Danny R. Hubbard II                Reference  No. 03-0048
Environmental Rernediation Systems, Inc.
P.O. Box 81905
Lafayette, Louisiana 70598

Dear Mr. Hubbard:

This responds to your letter requesting interpretation of this Office’s “position on measures for adequate training.” You inquired whether adequate training can be accomplished in eight hours or two days, and by purchase of a CD and literature be a self taught individual, who would then teach his/her employees?

The Research and Special Programs Administration (RSPA), the agency in the Department responsible for promulgating the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), intentionally made the requirements for training in Subpart H of Part 172 as broad and objective as is practicable to accommodate training programs and materials used in both the public and private sectors.  This approach provided the necessary latitude to both sectors for the development of effective training programs and/or materials.  It is RSPA’s position that responsible hazmat employers, either individually or through industry associations, are better able to determine the training needs of their employees.

The responsibility for ensuring that the level of training is adequate and appropriate for each hazmat employee is that of the employer; therefore, no attempt has been made to specify the level and duration of training or testing.  While responsibility for providing training remains with the employer, the required training can be provided by company training programs, self-guided CD training programs, outside training firms or consultants, Federal or State agencies, colleges and universities, or any other type of organization offering training that meets the objective training requirements.  This Office does not review or certify training programs for pre-approval purposes.

I hope this satisfies your inquiry



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


Regulation Sections

Section Subject
172.704 Training requirements