Interpretation Response #09-0099
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 16, 2009
Mr. Jim Lee
Oklahoma Historical Society
2401 North Laird Avenue
Oklahoma City, OK 73105-7914
Ref. No.: 09-0099
Dear Mr. Lee:
This responds to your letter regarding training requirements specified in Subpart H of Part 172 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the HMR specify qualifications for persons who provide such training.
There are no provisions under the training requirements in Subpart H of Part 172 for review and approval of training programs or certification of instructors. A hazmat employer must ensure that the training provided to its hazmat employees covers the training components specified in § 172.704(a) and that the person who provides the training is knowledgeable about the HMR and its application to specific operations and situations. Training that complies with the hazard communication programs required by the Occupational Safety and Health Administration (29 CFR 1910.120) may be used to satisfy the HMR training requirements to the extent that such training addressed the training components specified in § 172.704(a).
I hope this information is helpful. If we can be of further assistance, please contact us.
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards