{"operation":"document","citation":"17-0085","title":"Mr Evan Mills — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-12-28","effective_on":null,"summary":"17-0085 concerning 172.704.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0085.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0085.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0085","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/56876/170085.pdf","body":"<<<PAGE 1>>>\n\n2491 Matchlock Court\nWest Lafayette, IN 47906\nReference No. 17-0085\nDear Mr. Mills:\nThis letter is in response to your August 19, 2017, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training\nrequirements. You provide a scenario in which a hazardous materials (hazmat) employee\nreceived function-specific training related to the marking of specification cargo tanks prior to\nchanging job function, whereby the employee then received additional function-specific training\nto conduct periodic inspections of cargo tanks. After a period of six months, the hazmat\nemployee returned to his or her previous job function of marking specification cargo tanks.\nSpecifically, you ask if the hazmat employee must undergo function-specific training related to\nthe marking of specification cargo tanks again (i.e., does the change in job functions invalidate\nthe initial training). You note that this all occurs within the 3-year period before the recurrent\ntraining is required.\nThe answer is no. If the hazmat employee returns to his or her original job function of marking\nspecification cargo tanks and the function specific training is still valid for the 3-year period for\nrecurrent training in § 172.704(c)(2), then the hazmat employee is not required to repeat\nfunction-specific training until the end of the 3-year period for recurrent training or unless there\nare changes to the HMR or a special permit that are specifically applicable to the job function.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kindere\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nPlease submit this as a letter of interpretation. Mr. Mills spoke with Breanna. Please let me know if you have any\nquestions.\nThanks,\nJodi\nFrom: Evan Mills [mailto:evrmills@gmail.com]\nSent: Saturday, August 19, 2017 2:10 PM\nTo: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>\nSubject: Interpretation Letter Request\nU.S. DOT\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590\nTo Whom it May Concern:\nI am an individual seeking an official interpretation regarding the hazardous materials regulations (49 CFR parts 171-180). Specifically my\nquestion is regarding the training requirements under 172.704. I spoke with a representative at the Hazardous Materials Information\nCenter on 08/01/17 regarding the scenario below. I have included some clarifying notes based on our conversation.\nScenario:\nA hazmat employee is hired and trained according to the requirements set forth in 172.704 including general awareness, function-specific,\nsafety and security training within 90 days of employment. The hazmat employee was function-specific trained to properly mark\nspecification Cargo Tanks manufactured at this registered facility.\n1\n\n<<<PAGE 3>>>\n\nwithin the 3 year recurrent period is he required to be re-trained to that function?\nSincerely,\nEvan Mills\nevrmills@gmail.com\n(765)-202-0003\nAddress:\n2491 Matchlock Ct.\nWest Lafayette, IN 47906\n2","truncated":false,"body_characters":3099}