Training Requirements
Pipeline and Hazardous Materials Safety Administration · Jun 21, 1996 · Reference No. 96-0100
Interprets: 49 CFR § 172.700
Reggie’s quick take
A company asked whether its "Scale house" employees must get hazmat training under Subpart H of Part 172. Their jobs include weighing cargo tank trucks loaded with hot asphalt and lubricating oils, checking shipping papers, and checking placarding. PHMSA says yes. Because these tasks prepare hazardous materials for transport, the employees must be trained under Subpart H. The letter also notes that a final rule, published May 30, 1996, extended recurrent training from two years to three years.
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 1, 1996, regarding the requirements for training under the Hazardous Materials Regulations (HMR; 49 CFR; Parts 171-180).
In your letter, you commented on the Notice of Proposed Rulemaking (NPRM) published in the Federal Register under Docket HM-222B [61 FR 6478; February 20, 1996], and stated that you support the proposed change from two years to three years for recurrent training of a hazmat employee. You also requested an interpretation of whether a "Scale house" employee would be subject to the training requirements of Subpart H of Part 172.
A copy of your letter supporting the proposed change for recurrent training of a hazmat employee has been included in the public docket under HM-222B. For your information, on May 30, 1996, the final rule was published in the Federal Register [61 FR 27166], which reduced the frequency of recurrent training of hazmat employees from two years to three years (copy enclosed),
In response to your request for interpretation, persons who perform functions involving the transportation of hazardous materials must receive training applicable to those functions. Since your company's "Scale house" employees' job function is to weigh cargo tank trucks loaded with elevated temperature material (asphalt) and various lubricating oils, check shipping papers, and v placarding, which are functions involving preparation of hazardous materials for purposes of transportation, those employees must be trained as specified under Subpart H of Part 172.
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.