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Interpretation Response #09-0179 ([Union Tank Car Company] [Mr. Gary Alderson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Union Tank Car Company

Individual Name: Mr. Gary Alderson

Location State: PA Country: US

View the Interpretation Document

Response text:

September 17, 2009



Mr. Gary Alderson

Union Tank Car Company

P.O. Box 2003

Altoona, PA 16603

Ref. No. 09-0179

Dear Mr. Alderson:

This responds to your August 3, 2009 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training. Specifically, you ask if the quality assurance training specified in § 179.7(e) for employees of tank car facilities is subject to the same initial and recurrent training, testing, and recordkeeping requirements as specified in the general training requirements in Subpart H of Part 172.

The answer is yes. Section 179.7 requires each tank car facility to have a quality assurance program and specifies the minimum elements that must be included in the program. Each tank car facility must ensure that each employee is trained in accordance with Subpart H of Part 172 in the quality assurance program and procedures. Therefore, each employee must receive initial and recurrent training, each employee must be tested, and each tank car facility must maintain training records in the manner specified in Subpart H of Part 172.

I hope this information is helpful. If you have further questions, please contact this office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.702, 172.704 & 179.7

Regulation Sections

Section Subject
179.7 Quality assurance program