PHMSA letter of interpretation

Trainer Certification Requirements

Pipeline and Hazardous Materials Safety Administration · Nov 7, 2006 · Reference No. 06-0237

Interprets: 49 CFR § 172.704

Reggie’s quick take

Someone asked whether a hazmat instructor or consultant must be "certified" under the Hazardous Materials Regulations. PHMSA said no. The training rules in Subpart H of Part 172 have no process for approving training programs or certifying instructors.

Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.

This is in response to your July 17, 2006 letter regarding training certification requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether an instructor or consultant must be "certified" under the HMR.

The answer is no. There are no provisions or procedures under the training requirements in Subpart H of Part 172 for review and approval of training programs or certification of instructors.

I hope this information is helpful.

A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.