Hazmat Employee training for a Mail and Parcel Center (MPC)
Pipeline and Hazardous Materials Safety Administration · Oct 7, 2008 · Reference No. 08-0180
Interprets: 49 CFR § 171.8, 49 CFR § 172.704
Reggie’s quick take
A Mail and Parcel Center asked whether its employees must get hazmat training under Subpart H of Part 172. PHMSA said no, because the center neither accepts nor offers hazardous materials for transport in commerce. Its employees are not hazmat employees under § 171.8, and the center is treated as a shipper of non-regulated materials not subject to the HMR. PHMSA suggested the center may still want to train staff to spot packages that might contain hazardous materials. It also noted that FAA rules may apply to some parts of the operation.
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 10, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding training. Your scenario is based on a Mail and Parcel Center (MPC) that neither accepts nor offers hazardous material shipments for transportation in commerce. Your questions are paraphrased and answered below.
Q1. Are employees of the MPC described above required to be trained in accordance with Subpart H of Part 172?
A1. No. The hazardous materials training requirements in Subpart H of Part 172 of the HMR establishes training requirements for hazardous materials employees (hazmat employees). A hazmat employee is a person who, in the course of his employment, directly affects hazardous materials transportation safety (see § 171.8).
Q2. If training is not required for the employees of the MPC, how would DOT view the MPC, as a shipper, if the employees receive training in accordance with Subpart H of Part 172?
A2. As long as the MPC does not transport or offer hazardous materials for transportation in commerce, the DOT would view the MPC as a shipper of non-regulated materials who is not subject to the provisions of the HMR.
Although the HMR do not require your employees to be trained, you may wish to consider providing your employees with guidance or training to assist them to identify a package that may contain hazardous materials so that they do not inadvertently accept such a package for transportation.
You should also be aware that the Federal Aviation Administration has issued regulations governing air carriers that do not accept or transport hazardous materials, and these regulations may apply to some aspects of an MPC's operation. You may wish to contact
Mr. Christopher Bonanti, Director, Office of Hazardous Materials, ADG-1,
Federal Aviation Administration, 800 Independence Ave, SW, Room 300 East,
Washington, DC 20591, 202-267-9864, for additional information.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
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.