{"operation":"document","citation":"00-0118","title":"Department of Energy — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-06-12","effective_on":null,"summary":"00-0118 response to Department of Energy concerning 172.704.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0118.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0118.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0118","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000118.pdf","body":"<<<PAGE 1>>>\n\n•\nU.S.Department\nof Transportation\nJUN I 2 2000\nMr. Larry Blalock\nOffice of Transportation\nRef. No. 00-0118\nDepartment of Energy\nGermantown. MD 20874-1290\nDear Mr. Blalock:\nThis is in response to your letter dated April 14, 2000, requesting an update on the initial and recurrent\ntraining requirements in § 172.704. The four questions you asked essentially involve two issues: 1)\nwhether computer based training may be used to satisfy the training and recurrent requirements; and 2)\nwhether an employee may successfully take a test and have the recurrent training requirement waived.\nAs stated in our previous response to you dated July 20, 1994, an employer may use any type of\ntraining method, including a computer based program, that ensures each hazmat employee receives\ngeneral awareness/familiarization, function specific and safety training. Employees may be tested by any\nappropriate means on the training requirements specified in § 172.704. Recurrent training must cover\nthe three primary areas as specified for initial training, i.e., general awareness/familiarization, function\nspecific, and safety training. Therefore, an employee may not successfully take an exam and have the\nrecurrent training requirement waived.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nDuhun 765 elio\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n000118\n172.704\n\n<<<PAGE 2>>>\n\nDepartment of Energy\nengrum\nGermantown, MD 20874-1290\nITED\n$172.704\nAPR 1 4 2000\n00-0118\nMr. Ed Mazzulo, Director\nOffice of Hazardous Materials Standards\nResearch and Special Programs Administration\nU.S. Department of Transportation\n400 Seventh Street, S.W.\nWashington, DC 20590\nDear Mr. Mazzulo:\nWith reference to our June 9, 1994, letter and your July 20, 1994, (copies enclosed for ease of\nreference) response concerning clarification of acceptable methods to meeting the initial and\nrecurrent training requirement of 49 CFR 172.704, we would appreciate receiving an updated\nresponse to the following questions:\nQuestion 1 - Is it acceptable, for initial training, for a new hire which has received training from a\nprevious employer, but is unable to provide documentation, to \"challenge\" an exams) without\nreceiving some type of instruction from the current employer prior to taking the exams)?\nreceived initial training from his current hazardous material employer to \"challenge\" an exams)\nQuestion 2 - Is it acceptable, for recurrent training, for a current employee who has previously\nwithout receiving some type of additional instruction prior to taking the exams)?\nQuestion 3 - Is it permissible to utilize computer based training (CBT), which includes an\ninstruction section and an examination section, to meet the recurrent training requirements?\nQuestion 4 - Is it acceptable, for recurrent training, for a hazardous material employer to use a\ncomputer based program to develop a test from a randomly selected predetermined number of\nquestions from a large bank of relevant questions to \"test-out\" a current employee who has\npreviously received initial training from this employer?\n\n<<<PAGE 3>>>\n\n2\nYour clarification of these matters is appreciated.\nSincerely,\nLavy Blabach\nLarry G. Blalock\nOffice of Transportation\nOffice of Integration and Disposition\nEnclosures\nOffice of Environmental Management\nI. Mustin, EM-24\ncc:\nM. Williams, DOE-AL\nField Office Transportation Managers","truncated":false,"body_characters":3469}