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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 #22-0116

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

Interpretation Response Details

Response Publish Date:

Company Name: Total Technic

Individual Name: Total Technic

Location City: Istanbul Country: TR

View the Interpretation Document

Response text:

July 25, 2023

Total Technic
Maintenance Engineer
Total Technic
Ataturk International Airport
34149 Istanbul, Turkey

Reference No. 22-0116

Dear Mr. Demir:

This letter is in response to your October 27, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. We have paraphrased and answered your questions as follows:

Q1. You ask whether revisions to a special permit used by your employees necessitates an updated training of your hazmat employees.

A1. Section 172.704(a)(2) requires that each hazmat employee must be provided function-specific training concerning requirements of the HMR—or exemptions or special permits issued under subchapter A—that are specifically applicable to the functions the employee performs. As such, if the Pipeline and Hazardous Materials Safety Administration adopts a new regulation, changes an existing regulation, or revises a special permit that relates to a function performed by a hazmat employee, the employee must be instructed on those changes as needed. While it is not necessary to completely retrain the hazmat employee sooner than the required three-year cycle, the employee must receive the instruction necessary to ensure this person is knowledgeable about the new or revised regulatory requirement including changes to applicable special permits.

Q2. In your email, you describe a scenario in which one of your hazmat employees (Employee #1) conducts the training for all other hazmat employees (Employees #2-10) in your company. You ask whether Employee #1 may self-train or must be trained by another person.

A2. Employee #1 may self-train, provided the general awareness/familiarization training, function specific training, safety training, security awareness training, in-depth security training, testing, recordkeeping, and certification requirements specified in § 172.704 are met.

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

172.704, 172.704(a)(2)

Regulation Sections

Section Subject
172.704 Training requirements