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Interpretation Response #07-0126 ([REZ-1, Inc. (Boston)] [Mr. Mike Stern])

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

Interpretation Response Details

Response Publish Date:

Company Name: REZ-1, Inc. (Boston)

Individual Name: Mr. Mike Stern

Location State: MA Country: US

View the Interpretation Document

Response text:

February 25, 2008

Mr. Mike Stern


REZ-1Inc. (Boston)

395 Elliot Street

Newton, MA 02464

Ref. No. 07-0126

Dear Mr. Stern:

This responds to your letter requesting applicability of the training requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether under the following scenario a person is considered a hazmat employee and subject to training in accordance with the HMR:

Your company receives rail routing information, to include required hazardous materials descriptions, from a shipper via an online message or fax. Your company resends the information electronically to the railroad without any alteration in a billing format. Your company then sends the same unaltered information to the railroad via fax. You ask if these company employees are considered "hazmat employees" under the HMR and are required to be trained.

The company employees you describe in your letter would not be considered "hazmat employees" under the HMR and, therefore, would not be required to be trained.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.704, 171.8


Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.704 Training requirements