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Interpretation Response #09-0071

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

Interpretation Response Details

Response Publish Date: 06-17-2009
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
§ 172.704 Training requirements