General Information

Hazardous materials and dangerous goods regulations are developed and enforced to maintain national and international safety standards for the transportation of these articles and substances through various modes of transport.  Each mode of transport has it's own respective set of regulations which regulate shipping dangerous good by either air, ground, or vessel.

 

Do I Need Hazmat Training?

For United States purposes, all hazmat employees (§171.8, 49 CFR) who perform any of the following must be properly trained in the safe transportation of hazmat:

  • Loads, unloads or handles hazardous materials
  • Manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packagings as qualified for use in the transportation of hazardous materials
  • Prepares hazardous materials for transportation
  • Responsible for safety of transporting hazardous materials
  • Operates a vehicle to transport hazardous materials

The hazmat employer is responsible for providing this training, or may use a third-party trainer for this purpose. The U.S. DOT Hazardous Materials Regulations (HMR) does not offer any exemptions from hazmat training. Individuals who are self-employed and ship hazmat must be properly trained.

Those who transport or are involved with Dangerous Goods under IATA DGR and/or IMDG Code regulations must comply with the guidelines set forth for each respective authority of Dangerous Goods transport. While Dangerous Goods is not mandatory for shippers of Dangerous Goods using the IMDG Code, it is often required by vessel carriers as a condition of accepting shipments of Dangerous Goods aboard their cargo ships.

As such, it is in everyone's best interests and highly recommended to take the appropriate hazardous materials and Dangerous Goods training courses to comply.

 

Hazmat Training Requirements

All hazmat employees within the United States must be trained in the following areas dealing with hazardous materials (§172.704(a) 49 CFR, IATA 1.5.2 and 1.6):

  • General Awareness training: provides familiarity with the requirements and allows employees to recognize Dangerous Goods in the workplace,
  • Function-specific training: detailed job-specific training,
  • Safety training: includes emergency response and measures to be taken in case of an emergency at your workplace, and
  • Security training: security risks associated with hazardous materials transportation and enhancement of transportation safety.

 

What is a Hazmat Certification?

The U.S. DOT does not require hazmat employees to be "certified" in the traditional sense that an electrician or an accountant would be certified to perform their job functions properly. However, the U.S. DOT does require a hazmat employer to ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in Subpart H of 49 CFR (§172.702(a)).

 

Who is Considered a Hazmat Employee?

A hazmat employee is defined in 49 CFR as:

  1. A person who is
    • Employed on a full-time, part-time or temporary basis by a hazmat employer and who in the course of such full-time, part-time or temporary employment directly affects hazardous materials transportation safety;
    • Self-employed (including an owner-operator of a motor vehicle, vessel or aircraft) transporting hazardous materials in commerce who in the course of such self-employment directly affects hazardous materials transportation safety;
    • A railroad signalman;
    • Responsible for the safety of transporting hazardous materials; or
    • Operates a vehicle used to transport hazardous materials.
  2. This term includes an individual, employed on a full-time, part-time or temporary basis by a hazmat employer, or who is self-employed, who during the course of employment
    • Loads, unloads or handles hazardous materials
    • Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package, container or packaging component that is represented, marked, certified or sold by as qualified for use in transporting hazardous materials in commerce
    • Prepares hazardous materials for transportation
    • Is responsible for safety of transporting hazardous materials
    • Operates a vehicle used to transport hazardous materials

To complete a hazardous materials training curriculum, the following requirements must be satisfied for each hazmat employee:

  • §172.702(d) – Successfully complete a test regarding the required areas of hazmat training in §172.704(a), and
  • §172.704(d) – The hazmat employer must produce and retain a record of training for each hazmat employee currently employed, including their previous three years of training and 90 days after the hazmat employee has left.

Similarly, the IATA DGR requires that a test be taken to verify understanding of the regulations (1.5.0.4) and a record of training be kept for a minimum of 36 months from the most current completion date and be made available upon request by an appropriate national authority (1.5.5.2).

The IMDG Code does not specify the required aspects of Dangerous Goods "certification", but mentions that training records be kept by the employer and be provided to the employee upon request (1.3.1.3).

 

Initial Hazardous Materials and Dangerous Goods Training

For United States purposes under 49 CFR, a new hazmat employee, or a hazmat employee who has changed job functions, may still perform their job functions prior to the completion of a hazardous materials training curriculum (§172.704(c)(1)) provided that they are under the direct supervision of a properly trained and knowledgeable hazmat employee (§172.704(c)(1)(i)). The training curriculum must also be completed within 90 days of employment or change in job function (§172.704(c)(1)(ii)).

Under the IATA DGR regulations, initial training courses must be taken and maintained for:

  • Freight forwarders
  • Shippers of Dangerous Goods, including packers and persons and organizations undertaking the responsibilities of the shipper

Dangerous Goods training must be provided or verified upon the employment of personnel concerned with the transport of Dangerous Goods and identified with the minimum subject matter mentioned in IATA DGR Table 1.5.A.