Training Requirements
Pipeline and Hazardous Materials Safety Administration · May 6, 1997 · Reference No. 97-0108
Interprets: 49 CFR § 171.11, 49 CFR § 172.704
Reggie’s quick take
Someone asked how often a shipper must be re-trained when using the ICAO Technical Instructions, both for domestic and international shipments. PHMSA's answer is that such a shipper must be re-trained at least once every three years, under § 172.704(c). The shipper is not subject to the carrier training rules in the ICAO Technical Instructions, as provided in § 171.11.
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 January 21, 1997, regarding the training requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods. Specifically, you ask how often must a shipper who uses the ICAO Technical Instructions domestically, and internationally, be re-trained.
A shipper who uses the ICAO Technical Instructions for the transport of hazardous materials, domestically or internationally, must be re-trained at least once every three years in accordance with § 172.704(c). Although a shipper offers hazardous materials in accordance with the ICAO Technical Instructions, as provided in § 171.11 the shipper is not subject to the carrier training requirements of the ICAO Technical Instructions.
I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact us.
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.