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Interpretation Response #06-0255 ([Energy Solutions Federal Services] [Mr. James Portsmouth])

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

Interpretation Response Details

Response Publish Date:

Company Name: Energy Solutions Federal Services

Individual Name: Mr. James Portsmouth

Location State: WA Country: US

View the Interpretation Document

Response text:

Jan 4, 2007


Mr. James Portsmouth                  Reference No. 06-0255
Traffic Manager
Energy Solutions Federal Services
345 Hills Street
Richland WA, 993:54-5507

Dear Mr. Portsmouth:

This is in response to your October 26, 2006 letter requesting clarification of the applicability of training requirements provided in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask whether the training requirements contained in the HMR apply to employees who prepare shipments of hazardous waste for transportation in commerce when those employees are overseen by a person fully trained in accordance with Subpart H of Part 172.

The answer is yes. Except as provided in § 172.704(c)(1), hazmat employees who perform regulated functions must be trained in the HMR requirements that apply to that function (172.702(b)). Regulated functions include: (1) determining the hazard class of a material; (2) selecting an appropriate packaging; (3) filling a packaging; (4) securing packaging closures; (5) marking and labeling a package; and (6) preparing shipping Papers. Hazmat employees must receive general awareness, function specific, safety training, and security awareness training in accordance with Subpart H of Part 172. Training conducted to comply with requirements of the Occupational Safety and Health Administration, the Environmental Protection Agency, or other mandated training requirements may be used to the extent that such training satisfies the training, and testing requirements in Subpart H of Part 172.

I hope this information is helpful. Please contact us if you require additional assistance.



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


Regulation Sections

Section Subject
172.704 Training requirements