Department of Energy — Hazardous Materials Safety Interpretation

Page 1• U.S.Department of Transportation JUN I 2 2000 Mr. Larry Blalock Office of Transportation Ref. No. 00-0118 Department of Energy Germantown. MD 20874-1290 Dear Mr. Blalock: This is in response to your letter dated April 14, 2000, requesting an update on the initial and recurrent training requirements in § 172.704. The four questions you asked essentially involve two issues: 1) whether computer based training may be used to satisfy the training and recurrent requirements; and 2) whether an employee may successfully take a test and have the recurrent training requirement waived. As stated in our previous response to you dated July 20, 1994, an employer may use any type of training method, including a computer based program, that ensures each hazmat employee receives general awareness/familiarization, function specific and safety training. Employees may be tested by any appropriate means on the training requirements specified in § 172.704. Recurrent training must cover the three primary areas as specified for initial training, i.e., general awareness/familiarization, function specific, and safety training. Therefore, an employee may not successfully take an exam and have the recurrent training requirement waived. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Duhun 765 elio Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 000118 172.704#

Page 2Department of Energy engrum Germantown, MD 20874-1290 ITED $172.704 APR 1 4 2000 00-0118 Mr. Ed Mazzulo, Director Office of Hazardous Materials Standards Research and Special Programs Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, DC 20590 Dear Mr. Mazzulo: With reference to our June 9, 1994, letter and your July 20, 1994, (copies enclosed for ease of reference) response concerning clarification of acceptable methods to meeting the initial and recurrent training requirement of 49 CFR 172.704, we would appreciate receiving an updated response to the following questions: Question 1 - Is it acceptable, for initial training, for a new hire which has received training from a previous employer, but is unable to provide documentation, to "challenge" an exams) without receiving some type of instruction from the current employer prior to taking the exams)? received initial training from his current hazardous material employer to "challenge" an exams) Question 2 - Is it acceptable, for recurrent training, for a current employee who has previously without receiving some type of additional instruction prior to taking the exams)? Question 3 - Is it permissible to utilize computer based training (CBT), which includes an instruction section and an examination section, to meet the recurrent training requirements? Question 4 - Is it acceptable, for recurrent training, for a hazardous material employer to use a computer based program to develop a test from a randomly selected predetermined number of questions from a large bank of relevant questions to "test-out" a current employee who has previously received initial training from this employer?#

Page 32 Your clarification of these matters is appreciated. Sincerely, Lavy Blabach Larry G. Blalock Office of Transportation Office of Integration and Disposition Enclosures Office of Environmental Management I. Mustin, EM-24 cc: M. Williams, DOE-AL Field Office Transportation Managers#