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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #18-0089

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

Interpretation Response Details

Response Publish Date:

Company Name: ESHQ Services North America

Individual Name: Robert Miller

Location State: NJ Country: US

View the Interpretation Document

Response text:

August 20, 2018

Robert Miller
Manager – Transportation Safety
ESHQ Services North America
299 Jefferson Road
Parsippany, NJ  07054

Reference No. 18-0089

Dear Mr. Miller:

This letter is in response to your June 15, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements.  You describe a scenario in which a laboratory employee fills a sample bottle with a hazardous material and then hands the bottle to the shipping department.  The laboratory employee does not perform any other function related to transportation.  The shipping department employees are fully trained and perform all remaining pre-transportation functions.  You ask whether the laboratory employee must be trained in accordance with the hazardous material employee training requirements in Part 172 Subpart H.

The answer is yes.  As defined in § 171.8, a hazmat employee is a person who, in the course of his or her employment, directly affects hazardous materials transportation safety.  An employee who fills a packaging with a hazardous material is performing a function that directly affects transportation safety and, thus, is subject to the training requirements in Part 172 Subpart H of the HMR.  Note that training provided in accordance with standards or regulations of other Federal agencies, such as the Occupational Safety and Health Administration or the Environmental Protection Agency, may be used to satisfy the training requirements in § 172.704, provided such training addresses the training components specified in § 172.704(a).

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

171.8, 172, 172.704, 172.704(a)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.704 Training requirements