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.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.704(a)(2)
Regulation Sections
| Section | Subject |
|---|---|
| 172.704 | Training requirements |