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Interpretation Response #05-0245 ([Samirian Chemicals, Inc.] [Mrs. Debbie Andres])

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

Interpretation Response Details

Response Publish Date:

Company Name: Samirian Chemicals, Inc.

Individual Name: Mrs. Debbie Andres

Location State: CA Country: US

View the Interpretation Document

Response text:

Jan 17, 2006


Mrs. Debbie Andres                   Reference No. 05-0245
Samirian Chemicals, Inc.
1999 S. Bascom Ave.
Tower II, Suite 515
Campbell, CA 95008

Dear Mrs. Andres:

This is in response to your September 26, 2005, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the training requirements apply to employees who type addresses on shipping papers.

For purposes of the HMR, “hazmat employee” means a person who is employed by a hazmat employer and who, in the course of employment, directly affects hazardous materials transportation safety. In the specific scenario you describe, secretaries whose only function includes typing addresses on shipping papers while using unaltered templates that were created by a hazardous materials trained employee are not subject to the training requirements in Subpart H of Part 172. As described, these secretaries have no direct involvement in preparing the shipping documentation and do not handle, package, or load/unload hazardous materials for shipment, and therefore are not “hazmat employees” under the HMR.

I hope this satisfies your request.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.704 Training requirements