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Interpretation Response #15-0129 ([Crop Production Services, Inc] [Mr. Clayton Droste])

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

Interpretation Response Details

Response Publish Date:

Company Name: Crop Production Services, Inc

Individual Name: Mr. Clayton Droste

Location State: CO Country: US

View the Interpretation Document

Response text:

August 21, 2015

Mr. Clayton Droste
Manager, Commercial Motor Vehicle Compliance
Crop Production Services, Inc.
3005 Rocky Mountain Ave.
Loveland, CO 80538

Ref. No. 15-0129

Dear Mr. Droste:

This responds to your June 24, 2015 request for clarification on the emergency response information requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on whether the driver training requirements of § 177.816 require a driver to be familiar with and proficient in the use of the Emergency Response Guidebook (ERG), and based on the use of the ERG, be able to determine the appropriate course of action to take in the event of an emergency.

The HMR do not require a hazmat employee to have proficiency or familiarity with a specific source of emergency response information such as the ERG as part of safety training. Section 172.704(a)(3) requires each hazmat employee receive safety training concerning the emergency response information required by subpart G of part 172. A hazmat employer must determine the most suitable source of training for employees, based on specific job functions of each employee. Training on the ERG is only required to the extent that it satisfies the provisions of § 172.704(a)(3) and does not include proficiency in its use or the ability to determine, through its use, the appropriate course of action to take in the event of an emergency.

I trust this information is helpful. Please do not hesitate to contact us if you have any questions.



Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division


177.816, 172.704(a)(3)

Regulation Sections

Section Subject
172.704 Training requirements
177.816 Driver training