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Interpretation Response #10-0122 ([Energy Solutions] [Ms. Merrie Schilperoort])

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

Interpretation Response Details

Response Publish Date:

Company Name: Energy Solutions

Individual Name: Ms. Merrie Schilperoort

Location State: WA Country: US

View the Interpretation Document

Response text:

February 10, 2011




Ms. Merrie Schilperoort

Hazardous Materials Transportation

Training Manager

Energy Solutions

2345 Stevens Drive, Suite 240

Richland, WA 99354

Ref. No. 10-0122

Dear Ms. Schilperoort:

This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to record keeping requirements for training. Specifically, you ask whether a hazmat employer must be able to furnish on demand a copy of the test given to one of its hazmat employees used to satisfy its training responsibility under § 172.702(d). You indicate in your letter that such a requirement does not appear to be in accordance with the recordkeeping provisions for training prescribed in § 172.704(d).

The answer is no. As specified in § 172.702(d), a hazmat employer must ensure that each of its hazmat employees is tested by appropriate means on the training subjects covered in § 172.704. As specified in § 172.704(d), a record of current training, inclusive of the preceding three years, must be created and retained by a hazmat employer for as long as that employee is employed by that employer as a hazmat employee and for 90 days thereafter. At a minimum, the training record must include what is specified in paragraph (d); the test taken by a hazmat employee is not one of those items required to be retained.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division



Regulation Sections

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