Interpretation Response #17-0085
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
November 30, 2017
2491 Matchlock Court
West Lafayette, IN 47906
Reference No. 17-0085
Dear Mr. Mills:
This letter is in response to your August 19, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. You provide a scenario in which a hazardous materials (hazmat) employee received function-specific training related to the marking of specification cargo tanks prior to changing job function, whereby the employee then received additional function-specific training to conduct periodic inspections of cargo tanks. After a period of six months, the hazmat employee returned to his or her previous job function of marking specification cargo tanks. Specifically, you ask if the hazmat employee must undergo function-specific training related to the marking of specification cargo tanks again (i.e., does the change in job functions invalidate the initial training). You note that this all occurs within the 3-year period before the recurrent training is required.
The answer is no. If the hazmat employee returns to his or her original job function of marking specification cargo tanks and the function specific training is still valid for the 3-year period for recurrent training in § 172.704(c)(2), then the hazmat employee is not required to repeat function-specific training until the end of the 3-year period for recurrent training or unless there are changes to the HMR or a special permit that are specifically applicable to the job function.
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
|§ 172.704||Training requirements|