Department of Transportation
Hazardous Materials Training Requirements
Executive Briefing on the training requirements of 49 CFR 172.700
ship "consumer commodities", do I have to train my employees?
I hire temporary workers; must I train them all?
If I hire a packing company to prepare the shipment, do I still
have to train my employees?
These are very common questions. This briefing paper will explain
the DOTs requirement for hazmat employers to train their employees.
What companies are effected by this law?
Any company that ships, offers for shipment, or accepts hazardous
materials for transport. This includes companies such as brokers
and forwarders who many not even physically handle the freight,
but act as an "offeror" of hazmat to a carrier.
What commodities are effected by this law?
Anything that is considered a hazardous material. Examples include:
Aerosols (i.e. spray paint), dry ice, batteries, cosmetics, safety
equipment, medical or cleaning supplies, the list includes thousands
of commonly shipped items that meet the criteria of one or more
of the 9 hazard classes.
Which employees of mine have to be trained?
Any person who directly effects the safety of a hazardous material
in transportation is classified as a "hazardous materials employee."
When does this training have to be done?
All employers MUST train and TEST every hazardous materials employee
within 90 days on the job. Recurrent training is required every
two to three years and may be required sooner if they change job
categories. Temporary workers can work under the supervision of
a trained employee for up to 90 days.
What type of training is required?
The law requires these types of training:
* Function Oriented Training
* General Awareness Training
* Safety Training
degree of training that an employee requires is determined by his
job responsibilities. A driver for example, may require "functional"
training on loading and handling dangerous goods, cargo compatibility,
shipping papers, and emergency response procedures, among others.
Also, this rule requires recurrent training every three years or
whenever the regulations change that effect the job function, whichever
What does it mean to be "certified"
This means that the employer has certified that the employee is
properly trained for their job function.
Can I train my employees by computer?
Is there such as thing as "DOT Certification"
Not in the sense that the DOT is the one certifying your employee
that is strictly an employer responsibility and neither the DOT
nor their agencies (i.e. the FAA) get involved in certifying employees.
There is no government approval of training programs or instructors
for shipper or forwarders. This is an area that is often confused;
please give us a call for more
information on this important topic.