Interpretation Response #17-0085

 

 

November 30, 2017

 

Evan Mills

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.

 

Sincerely,

 

 

 

Dirk Der Kinderen

Chief, Standards Development Branch

Standards and Rulemaking Division

 

172.704(c)(2)