USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #08-0200 ([Shane Havoc Consulting, LLC] [Mr. Gregory Sutherland])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shane Havoc Consulting, LLC

Individual Name: Mr. Gregory Sutherland

Location State: SC Country: US

View the Interpretation Document

Response text:

September 16, 2008

Mr. Gregory Sutherland

Shane Havoc Consulting, LLC

1905 English Ivy Court

Mount Pleasant, SC 29464

Ref. No. 08-0200

Dear Mr. Sutherland:

This responds to your July 26, 2008, letter requesting clarification of the training requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Specifically, you ask whether employees of a computer software development firm that has been retained to develop a computer program to generate shipping papers must be trained in accordance with Subpart H of Part 172 of the HMR.

If the computer programmers employed by the software development firm merely input data concerning the hazardous materials to be shipped (e.g., proper shipping names, classification, authorized packagings) provided to them by a trained hazmat employee of the client company, then the computer programmers are not considered hazmat employees, and the training requirements in Subpart H of Part 172 do not apply. However, if the computer programmers make determinations concerning regulatory requirements applicable to the hazardous materials to be shipped as part of the development of the shipping paper software, then the computer programmers are considered to be hazmat employees and must be trained.

I hope this answers your inquiry.


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

Subpart H 172.700

Regulation Sections

Section Subject
172.700 Purpose and scope