Updating Security Plans
Pipeline and Hazardous Materials Safety Administration · Apr 3, 2023 · Reference No. 22-0109
Interprets: 49 CFR § 172.704(a)(5), 49 CFR § 172.704(c)(2), 49 CFR § 172.800(b)
Reggie’s quick take
A company asked whether small edits to its hazmat security plan would force it to retrain employees within 90 days. PHMSA said no. Editorial changes, such as fixing misspellings, and clarifications that do not change the plan's intent or actions do not require retraining under § 172.704(c)(2). The letter does not say whether a substantive revision would trigger the 90-day retraining rule in § 172.704(a)(5).
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.
April 3, 2023
Reference No. 22-0109
This letter is in response to your September 12, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to security plans. In your email, you state that your company is required to have a security plan as specified in 172.800(b) of the HMR. You also state that 172.704(c)(2) requires that a hazardous materials (hazmat) employee shall receive recurrent training at least once every three years. Lastly, you state that a hazmat employee must receive the in-depth security training required under 172.704(a)(5) at least once every three years or—if the security plan for which training is required is revised during the three-year recurrent training cycle—within 90 days of implementation of the revised plan. Based on these statements, we have paraphrased your questions and answered them in the order you provided:
Q1. You ask whether revisions to a security plan—such as correcting misspellings—would require the retraining of a hazmat employee within 90 days of such a revision in order for a hazmat employer to comply with 172.704(a)(5) and (c)(2).
A1. The answer is no. Editorial revisions to a security plan—including correcting misspellings—would not necessitate a hazmat employer to retrain a hazmat employee in order to comply with the recurrent training requirements specified in 172.704(c)(2).
Q2. You ask whether clarifications that do not change the intent or actions within a security plan would necessitate a hazmat employer to retrain a hazmat employee in order to comply with the recurrent training requirements specified in § 172.704(c)(2).
A2. The answer is no. See answer A1.
I hope this information is helpful. Please contact us if we can be of further assistance.
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.