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Interpretation Response #09-0051 ([Hazard Solutions LLC] [Mr. Arthur Mahoney])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazard Solutions LLC

Individual Name: Mr. Arthur Mahoney

Location State: CA Country: US

View the Interpretation Document

Response text:

March 26, 2009

Mr. Arthur Mahoney


Hazard Solutions LLC

326 Sonora Drive

San Mateo, CA 94402

Ref. No.: 09-0051

Dear Mr. Mahoney:

This responds to your February 11, 2009, letter requesting clarification of the training requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Specifically, you ask if an employee who assembles a package of hazardous materials which he then offers to the shipping department for final closure is subject to training requirements.

According to your letter, employees submit a shipping request to your company"s shipping department describing the hazardous materials they want to ship. The trained shipping department employees provide the packaging materials and instructions (typically provided by the packaging manufacturer) on how to package the hazardous materials. The employees place the hazardous materials in the package as instructed, sealing the primary containers, but leaving the outer packaging unsealed for inspection by the shipping department. You ask if the employees who place the hazardous materials in the package are subject to the training requirements in the HMR.

The answer is yes. Employees who package hazardous materials for transportation are hazardous materials employees, as defined in § 171.8 of the HMR. In accordance with § 172.702, no hazardous materials employee may perform a function subject to HMR requirements unless instructed in the requirements that apply to that function. Specific training requirements are in § 172.704.

I hope this answers your inquiry.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

171.8, 172.704, 172.702

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.702 Applicability and responsibility for training and testing
172.704 Training requirements