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Interpretation Response #99-0204 ([Baker Hughes] [Ms. Shelley A. Espinoza])

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

Interpretation Response Details

Response Publish Date:

Company Name: Baker Hughes

Individual Name: Ms. Shelley A. Espinoza

Location State: TX Country: US

View the Interpretation Document

Response text:

November 1, 1999


Ms. Shelley A. Espinoza                         Ref.  No. 99-0204
Baker Hughes
Post Office Box 1407
Houston, Texas 77251-1407

Dear Ms. Espinoza:

This is in response to your letter dated July 16, 1999, regarding the definition of a “hazmat employee” in 49 CFR 171.8 as it applies to an individual performing evaluation of documentation accompanying a cylinder assembly under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  The employee is not involved in the manufacturing process, assembly, testing, marking, packaging or transportation of the cylinders.

Based on the information provided in your letter, when an employee of your company is responsible for evaluating documentation accompanying a cylinder assembly (assembly is inspected and verified by an independent inspection agency prior to the evaluation) to determine if the components of the assembly meet the quality and design standards authorized for transportation under a DOT exemption, such an employee is a "hazinat employee," as defined in 49 CFR 171.8. Each “hazmat employee” who performs a function subject to the exemption must receive training on the requirements and conditions of the exemption in addition to the training required by 49 CFR 172.700 through 172.704.

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
171.8 Definitions and abbreviations