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Interpretation Response #18-0021

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

Interpretation Response Details

Response Publish Date:

Company Name: TMC Engineering Services, Inc.

Individual Name: Steven Geneva

Location State: TX Country: US

View the Interpretation Document

Response text:

May 17, 2018

Steven Geneva
Director of Quality Assurance and Regulatory Compliance
TMC Engineering Services, Inc.
2335 Wadsworth Street
Houston, TX 77015

Reference No. 18-0021

Dear Mr. Geneva:

This letter is in response to your February 20, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to function‑specific training. Specifically, you provide a list of functions your employees perform and seek confirmation of your understanding of the function‑specific training requirements in the HMR.

In accordance with § 172.702 of the HMR, it is the hazmat employer's responsibility to ensure that each of its hazmat employees is trained. This training must include general awareness, function-specific, safety, and security awareness training as specified in § 172.704(a). Generally, this Office does not review individual training plans for compliance; however, the training program as described in your email appears to conform to the requirements of the HMR.

Function-specific training is specific to the function(s) for which the hazmat employee is responsible. Please note that function-specific training includes training concerning the requirements of special permits that are specifically applicable to the functions the employee performs. See § 172.704(a)(2)(i). Training conducted to comply with the hazard communication programs required by the Occupational Safety and Health Administration (29 CFR 1910.120) or the Environmental Protection Agency (40 CFR 311.1) or training that complies with security training programs required by other Federal or international agencies may be used to satisfy the training requirements set forth in § 172.704 to the extent that such training addressed the training components specified in § 172.704(a).

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


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

Regulation Sections

Section Subject
172.702 Applicability and responsibility for training and testing
172.704 Training requirements