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Interpretation Response #15-0213

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

Interpretation Response Details

Response Publish Date: 03-29-2016
Company Name: Independent Cylinder Training    Individual Name: Ms. Amy Bruecks
Location state: OK    Country: US

View the Interpretation Document

Response text:

March 29, 2016

Ms. Amy Morgan Bruecks
Independent Cylinder Training
406 S.W. 4th Street
Oklahoma City, OK  73109

Reference No. 15-0213

Dear Ms. Bruecks:

This letter is in response to your October 14, 2015 e-mail and letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to recurrent training requirements for hazmat employees as prescribed in § 172.704(c)(2).  Specifically, you ask if hazmat employees who perform eddy current examinations of Department of Transportation (DOT) 3AL specification cylinders in conformance with the requirements prescribed in 49 CFR Appendix C to Part 180 - Eddy Current Examination with Visual Inspection for DOT 3AL Cylinders Manufactured of Aluminum Alloy 6351-T6, are required to receive recurrent hazmat training every three years as prescribed in § 172.704(c)(2).

The answer is yes.  Section 8 of 49 CFR Appendix C to Part 180 requires each person who performs eddy current and visual examinations, and evaluates and certifies the retest results as prescribed must be certified by the employer that he or she has been properly trained and tested to properly perform these procedures.  Further, the approval letters the Pipeline and Hazardous Materials Safety Administration issues to grant individuals the authority to eddy current test a cylinder in conformance with 49 CFR Appendix C to Part 180 require each “hazmat employee,” as defined in § 171.8, who performs a function subject to that approval to receive appropriate training in accordance with § 172.702.  Section 172.702(a) requires a hazmat employer to ensure each of its hazmat employees is trained in conformance with the requirements prescribed in 49 CFR Part 172, Subpart H, which includes the requirement for hazmat employees to receive recurrent function-specific hazmat training every three years as specified in § 172.704.  

I hope this information is helpful.  Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

172.704(c)(2), 172.702, 172.702(a), 172.704

Regulation Sections

Section Subject
§ 172.704 Training requirements