Interpretation Response #18-0093
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
November 27, 2018
David J. Ronzani
Director, Railcar Regulatory Compliance
1101 W. 31st Street, Suite 200
Downers Grove, IL 60515
Reference No. 18-0093
Dear Mr. Ronzani:
This letter is in response to your June 19, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to employee training requirements. Specifically, you ask whether an employee must be trained and tested on each leak test procedure they may use, or if being generally trained on comparable topics, such as the quality assurance program and procedures as outlined in § 179.7(e), is sufficient.
The HMR do not require any specific training curriculum; instead, training must fulfill the requirements outlined in § 172.704. If the hazmat employer determines that providing generic leak test training as part of the quality assurance program is sufficient to fulfill training requirements, more specific training is unnecessary to fulfill the employee's job function. Each hazmat employer has its own unique operational requirements. Therefore, it is the responsibility of a hazmat employer to determine the specific training needs of its hazmat employees based on the employee's specific job functions. It is also the responsibility of the hazmat employer to ensure and certify that each hazmat employee receives function-specific training concerning requirements of the HMR, which are specifically applicable to the functions the employee performs. See § 172.704(a)(2).
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
179.7(e), 172.704, 172.704(a)(2)
|§ 172.704||Training requirements|