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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 #23-0057

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

Interpretation Response Details

Response Publish Date:

Company Name: WMG Inc.

Individual Name: Mr. John Grinley

Location State: FL Country: US

View the Interpretation Document

Response text:

September 28, 2023

Mr. John Grinley
WMG Inc.
5391 Lakewood Ranch Blvd
Suite 302
Sarasota, FL  34240

Reference No. 23-0057

Dear Mr. Grinley:

This letter is in response to your June 6, 2023, email and a subsequent phone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. Specifically, you ask whether training on the software used to generate hazardous materials shipping papers must be provided to a hazardous materials (hazmat) employee in accordance with the "Function-specific" training requirements specified in § 172.704(a)(2).

The answer is yes. Function-specific training is required for the function(s) for which a hazmat employee is responsible. Therefore, if a hazmat employee must use a specific software to perform functions pertaining to the requirements of the HMR - such as classifying materials or generating hazardous materials shipping papers – the hazmat employee must be trained on that software.

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
172.704 Training requirements