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Interpretation Response #99-0148 ([Products, Inc.] [Mr. Gene Secor])

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

Interpretation Response Details

Response Publish Date:

Company Name: Products, Inc.

Individual Name: Mr. Gene Secor

Location State: MI Country: US

View the Interpretation Document

Response text:

February 24, 2000

Mr. Gene Secor                        Ref.  No. 99-0148
H. B. Fuller Automotive
Products, Inc.
31601 Research Park Drive
Madison Heights, Michigan 48071

Dear Mr. Secor:

This is in response to your letter regarding the training requirements as they apply to sales people who are considered "hazmat employees" under the requirements of Subpart H of Part 172 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  We apologize for the delay in responding and hope it has not caused any inconvenience.

You asked whether a "hands-on demonstration" is required, or if a "kit" consisting of the correct UN packaging, including inner containers, etc., and a "cheat sheet" on how to construct or prepare the package would satisfy the requirements for "function specific" training.  For example, if sales people not physically located near a plant or warehouse were provided such a "kit", would this be acceptable to meet "function specific" training?  Competency would be certified by your company.

The purpose of the training requirements is to ensure that each hazmat employer trains each hazmat employee.  There are no provisions or procedures under the training requirements for review or approval of training programs or certification of instructors.  A hazmat employer must determine the most suitable method (e.g., hands-on demonstrations) and source of training for its employees.

Although self-training is acceptable and may be used, a "cheat sheet" in and of itself is not "training" and may not be sufficient to provide the knowledge level necessary to construct and prepare a package for hazardous materials.  In addition, each hazmat employer must certify that each of its hazmat employees has been trained and tested, as required.  No specific testing method or document is required.  The requirements in Subpart H of Part 17J do not state that an employee must "pass" a test; however, a hazmat employee may only be certified in those areas in which the hazmat employee can successfully perform the assigned duties.  A record of current training must be created and retained by each hazmat employer as specified in 49 CFR 172.704(d).

For your information, enclosed is a previous letter of clarification which answers many of the questions you may have regarding a hazmat employee's training.

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.704 Training requirements