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Interpretation Response #11-0293 ([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:

May 30, 2012


Mr. Michael Gardner
Manager of Safety Compliance
Con-Way Freight
2211 Old Earhart Road
Ann Arbor, MI 48105

Ref. No. 11-0293

Dear Mr. Gardner:

This responds to your November 14, 2011 request for further clarification of your March 2, 2011 letter of clarification under Ref. No. 11-0063 on the recurrent training requirements under § 172.704(c)(2) of 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 individual training annually over the course of a 3-year period instead of providing complete recurrent training to all hazmat employees every 3 years.

We have reviewed your follow up letter with additional clarifying information. Based on the training records you provided with your letter, it is the opinion of this office that the partial training over the 3-year recurrent training cycle is not prohibited by the HMR provided the training includes all required components specified in § 172.704(a). Recurrent training must be completed within the 3-year recurrent training period and each partial training element must be repeated at least every 3 years. You should also note, although not prohibited, completing partial training sessions creates different recurrent training dates for each session which could be burdensome for recordkeeping.

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



Ben Supko
Senior Regulations Officer
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.704 Training requirements