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Interpretation Response #11-0063 ([Con-Way Freight] [Mr. Michael Gardner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Con-Way Freight

Individual Name: Mr. Michael Gardner

Location State: MI Country: US

View the Interpretation Document

Response text:

August 22, 2011




Mr. Michael Gardner

Manager of Safety Compliance

Con-Way Freight

2211 Old Earhart Road

Ann Arbor, MI 48105

Ref. No. 11-0063

Dear Mr. Gardner:

This responds to your March 2, 2011 request for clarification on the recurrent training requirements under § 172.704(c)(2) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if it would be acceptable for an employer to provide partial recurrent training annually over the course of a three-year period instead of providing complete recurrent training to all hazmat employees every three years.

The answer is no. The HMR do not specifically authorize partial training annually to meet the

3-year recurrent training requirement.

Section 172.704(c)(2) requires a hazmat employee to receive the training at least once every three years. In addition, if major regulatory changes occur within this 3-year recurrent training period, hazmat employees must receive training on the new regulatory requirements within 90 days of their effective date. Section 172.704(a)(1)-(4) requires hazmat training to include: general awareness/familiarization training; function-specific training; safety training; and security awareness training. Additionally, § 172.704(a)(5) requires in-depth security training when a security plan is required by part 172, subpart I.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.


Ben Supko

Chief, Standards Development

Standards and Rulemaking Division


Regulation Sections

Section Subject
172.704 Training requirements