DOT and PHMSA issue new enforcement policy regarding recurrent training requirements in response to COVID-19

On 25 March 2020 the U.S. Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published a new enforcement policy regarding recurrent training requirements for hazardous materials employers in light of the international novel coronavirus outbreak (COVID-19).

Specifically, the new policy states that PHMSA will not pursue enforcement actions against any hazardous materials (hazmat) employer who is unable to procure and/or provide recurrent training required by the Hazardous Materials Regulations (HMR). According to the notice, the new policy was put in place "in response to unprecedented changes in business practices related to the COVID-19 outbreak and is intended to minimize disruptions to the supply chain."

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