UPDATE: Looking at Hazmat Employee Training as Addressed in PHMSA Letters of Interpretations

摘要

The above examples of PHMSA interpretations related to the training of hazmat employees should provide guidance in determining whether or not an employee is a hazmat employee under the HMR. As can be seen, if you have to ask, your employees probably do meet the hazmat employee definition. However, if you are in the process of evaluating whether you or your employees meet the hazmat definitions, based on one or more of the above 18 examples, I suggest the following: 1. Review the PHMSA letter of interpretation as issued, since most of the above examples have been shortened and edited from the original. This can be done by entering the interpretation's reference number on either The Journal's website or PHMSA's online interpretations database. (Note that The Journals website automatically links to any related comments on an interpretation that may have been provided in past editions of The Journal.)