Training Requirements for Vessel Transportation
Pipeline and Hazardous Materials Safety Administration · Jun 7, 1995 · Reference No. 95-0140
Reggie’s quick take
Someone asked whether several kinds of maritime workers need hazmat training under the Hazardous Materials Regulations. PHMSA said a worker is a "hazmat employee" under § 171.8 based on whether their job functions affect hazmat transport safety, not just on being near hazmat. Employers decide what training each person needs. Export packers who pack hazmat for international shippers are covered. So are shore side staff of ship owner operators who prepare shipping papers. Steamship agents and crew doing engine repair or valve changes are not. For hazmat carried in tankers and bulk carriers, HMR training does not apply, because 46 CFR governs.
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 letter dated April 28, 1995 concerning applicability of training as required by the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
The term "hazmat employee," as defined in § 171.8, includes all persons who in the course of employment perform functions that directly affect hazardous materials transportation safety. Conversely, this term does not apply to every employed person who works at or around an area where, for example, hazardous materials are loaded, unloaded, handled, or stored. The employee's functional relationship to the HMR, rather than incidental contact with hazardous materials in the work place is the primary factor in determining whether an individual is a "hazmat employee."
Each hazmat employee may have unique requirements. Based on those requirements and the specific job functions of each employee, the hazmat employer must determine what level of training, if any, is required. Hazmat employers may decide how training is to be presented.
Based on the information provided, your questions are paraphrased and answered as follows:
1Q. Are the following employees subject to the training requirements?
a) Steamship agents who travel to and from vessels transporting hazardous materials -- do not physically transport hazardous materials, but may carry dangerous cargo manifests to the vessels, and participate in the docking arrangements to place vessels at hazardous materials terminals.
No.
b) Export packers -- receive and pack hazardous materials for international shippers.
Yes.
c) Foreign ship owner operators' shore side personnel -- responsible for scheduling, preparing shipping papers, and supervising preparation of stowage plans and dangerous cargo manifests. U.S. ship owner operators (whether operating U.S. or foreign vessels)?
Yes.
e) Ship crew or others involved in engine repair, changing of valves.
No.
2Q. Do the requirements for training apply to chemical/oil tankers and other hazardous materials bulk carriers?
A. Hazardous materials transported by water in tankers and bulk carriers (except as defined in § 171.8) are regulated by 46 CFR. Training required under the HMR does not apply.
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.