Mr Evan Mills — Hazardous Materials Safety Interpretation

Page 12491 Matchlock Court West Lafayette, IN 47906 Reference No. 17-0085 Dear Mr. Mills: This letter is in response to your August 19, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements. You provide a scenario in which a hazardous materials (hazmat) employee received function-specific training related to the marking of specification cargo tanks prior to changing job function, whereby the employee then received additional function-specific training to conduct periodic inspections of cargo tanks. After a period of six months, the hazmat employee returned to his or her previous job function of marking specification cargo tanks. Specifically, you ask if the hazmat employee must undergo function-specific training related to the marking of specification cargo tanks again (i.e., does the change in job functions invalidate the initial training). You note that this all occurs within the 3-year period before the recurrent training is required. The answer is no. If the hazmat employee returns to his or her original job function of marking specification cargo tanks and the function specific training is still valid for the 3-year period for recurrent training in § 172.704(c)(2), then the hazmat employee is not required to repeat function-specific training until the end of the 3-year period for recurrent training or unless there are changes to the HMR or a special permit that are specifically applicable to the job function. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kindere Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Please submit this as a letter of interpretation. Mr. Mills spoke with Breanna. Please let me know if you have any questions. Thanks, Jodi From: Evan Mills [mailto:evrmills@gmail.com] Sent: Saturday, August 19, 2017 2:10 PM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov> Subject: Interpretation Letter Request U.S. DOT Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590 To Whom it May Concern: I am an individual seeking an official interpretation regarding the hazardous materials regulations (49 CFR parts 171-180). Specifically my question is regarding the training requirements under 172.704. I spoke with a representative at the Hazardous Materials Information Center on 08/01/17 regarding the scenario below. I have included some clarifying notes based on our conversation. Scenario: A hazmat employee is hired and trained according to the requirements set forth in 172.704 including general awareness, function-specific, safety and security training within 90 days of employment. The hazmat employee was function-specific trained to properly mark specification Cargo Tanks manufactured at this registered facility. 1#

Page 3within the 3 year recurrent period is he required to be re-trained to that function? Sincerely, Evan Mills evrmills@gmail.com (765)-202-0003 Address: 2491 Matchlock Ct. West Lafayette, IN 47906 2#