49 CFR (DOT) Hazmat Training Requirement by Law (USA)
Training is the best means of preventing or reducing hazardous materials (hazmat) incidents in transportation that are caused by human error.
The Federal hazardous materials transportation law (49 U.S.C. 5101, et seq.) is the statute pertaining to the transportation of hazmat in the United States and requires the training of ALL hazmat employees. In transportation, the terms “hazardous materials” and “dangerous goods” are synonymous and interchangeable; “hazardous materials” is the U.S. Department of Transportation’s term for what is referred to as “dangerous goods” in the international standards.
Both terms refer to substances or articles that pose a hazard to health, safety, property, or the environment when transported in commerce; if you are involved in their preparation or transportation, national and international regulations state that you must be trained. This training aims to increase a hazmat employee’s safety awareness and to be an essential element in reducing hazmat incidents.
Who Needs Hazmat Training?
Anyone who either:
- Transports hazardous materials in commerce
- Offers hazardous materials for commerce
- Causes hazardous materials to be transported in commerce
- Performs pre-transportation functions
H.M.R. Training Requirements for Hazmat Employees?
The Hazardous Materials Regulations (H.M.R.) includes training requirements in several sections of Title 49 Code (Subpart H – 49 CFR 172.704) of Federal Regulations (C.F.R.) as follows:
General awareness/familiarization training (49 CFR 172.704(a)(1)) Provides knowledge of the H.M.R. and its requirements and enables a hazmat employee to recognize and correctly identify hazardous materials.
- Function-specific training (49 CFR 172.704(a)(2)):
Function-specific training relates to the requirements of D.O.T. regulations for shippers, transporters and manufacturers that specifically apply to the functions the employee performs. For example, packaging, markings, labelling, placarding, etc.)
- Safety training (49 CFR 172.704(a)(3))
Addresses emergency response information measures to protect an employee from the hazards of exposure to hazardous materials, as well as methods and procedures for avoiding accidents.
- Security awareness training (49 CFR 172.704(a)(4))
Security awareness training relates to security risks associated with transporting hazardous materials and the methods designed to enhance transportation security. This training must also include how to recognize and respond to possible security threats.
- In-depth security training (if a security plan is required)
- Driver Training
For each hazmat employee who will operate a motor vehicle
How Frequently Do Employees Need Training?
A new hazmat employee or a hazmat employee who changes job functions must complete training requirements for the new job function(s) within 90 days. However, the employee may perform new hazardous materials job functions before completing training, provided the employee performs those functions under the supervision of an appropriately trained and knowledgeable hazmat employee.
Hazmat employees must receive the required training at least once every three years. For the in-depth security training required, a hazmat employee must be trained at least once every three years or, if the security plan for which training is required is revised during the three-year recurrent training cycle, within 90 days of implementation of the revised plan.
Training Records
Training records must be kept by the hazmat employer for each hazmat employee and must include the following:
- the hazmat employee’s name;
- the completion date of the most recent training;
- training materials used (copy, description, or location);
- the name and address of the hazmat trainer; and
- certification that the hazmat employee has been trained and tested.
Training records must be retained for each hazmat employee for three years from the last training date, and for 90 days after the employee leaves.