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Interpretation Response #09-0071 ([Oncology Supply Company] [Mr. Brad King Regulatory])

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

Interpretation Response Details

Response Publish Date:

Company Name: Oncology Supply Company

Individual Name: Mr. Brad King Regulatory

Location State: OK Country: US

View the Interpretation Document

Response text:

June 16, 2009



Mr. Brad King

Regulatory Compliance Manager

Oncology Supply Company

2801 Horace Shepard Drive

Dothan, Al 36303

Ref. No.: 09-0071

Dear Mr. King:

This responds to your e-mail letter regarding the requirements for training under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about training requirements for employees preparing materials for transportation in accordance with a special permit.

In accordance with § 172.702 of the HMR, a hazmat employer must ensure that each of its hazmat employees is trained. This training must include general awareness, function-specific, safety, and security awareness training as specified in § 172.704(a). Note that function-specific training includes training concerning the requirements of special permits that are specifically applicable to the functions the employee performs. See § 172.704(a)(2)(i)). Training conducted to comply with the hazard communication programs required by the Occupational Safety and Health Administration (29 CFR 1910.120) or the Environmental Protection Agency (40 CFR 311.1) or training that complies with security training programs required by other Federal or international agencies may be used to satisfy the training requirements set forth in § 172.704 to the extent that such training addressed the training components specified in § 172.704(a).

Under the HMR, each hazmat employer must certify that each of its hazmat employees has been trained and tested, as required. A record of current training must be created and retained by each hazmat employer as specified in § 172.704(d).

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.702, 172.704

Regulation Sections

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