Hazmat Training Requirements

Hazmat Training Requirements

§172.700–§172.704

The purpose of the training requirements in Part 172 Subpart H of the Hazardous Materials Regulations (HMR) is to ensure that each hazmat employer trains its hazmat employees to safely load, unload, handle, store and transport hazardous materials.

A hazmat employer must train, test and certify every hazmat employee who, in the course of employment, has any function that directly affects hazardous materials transportation safety.

Definitions §171.8

Hazmat employer means:

(1) A person who employs or uses at least one hazmat employee on a full-time, part time, or temporary basis; and who:

(i) Transports hazardous materials in commerce;

(ii) Causes hazardous materials to be transported in commerce; or

(iii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package, container, or packaging component that is represented, marked, certified, or sold by that person as qualified for use in transporting hazardous materials in commerce;

(2) A person who is self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting materials in commerce; and who:

(i) Transports hazardous materials in commerce;

(ii) Causes hazardous materials to be transported in commerce; or

(iii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package, container, or packaging component that is represented, marked, certified, or sold by that person as qualified for use in transporting hazardous materials in commerce; or

(3) A department, agency, or instrumentality of the United States Government, or an authority of a State, political subdivision of a State, or an Indian tribe; and who:

(i) Transports hazardous materials in commerce;

(ii) Causes hazardous materials to be transported in commerce; or

(iii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package, container, or packaging component that is represented, marked, certified, or sold by that person as qualified for use in transporting hazardous materials in commerce.

Hazmat employee means: (1) A person who is:

(i) 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;

(ii) 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;

(iii) A railroad signalman; or

(iv) A railroad maintenance-of-way employee.

(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:

(i) Loads, unloads, or handles hazardous materials;

(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.

(iii) Prepares hazardous materials for transportation;

(iv) Is responsible for safety of transporting hazardous materials;

(v) Operates a vehicle used to transport hazardous materials.

Hazmat Training §172.704

Hazardous materials training must include general awareness/familiarization, function-specific, safety, security awareness, in-depth security, and modal specific training (such as Driver Training).

General Awareness/Familiarization Training §172.704(a)(1)

Each hazmat employee must receive general awareness/familiarization training designed to provide familiarity with the HMR requirements and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards in the regulations.

Function-Specific Training §172.704(a)(2)

Each hazmat employee must receive function-specific training concerning the regulations specifically applicable to the functions the employee performs. The specific training will vary depending on the individual's specific job functions. What is needed by a shipping clerk, a driver, the compliance officer, even the person who prepares the shipping papers, will vary in the detail according to what functions they are performing.

Note: A railroad maintenance-of-way employee or railroad signalman who does not perform any function subject to the regulations, does not have to receive function-specific training.

Safety Training §172.704(a)(3)

Each hazmat employee must receive safety training concerning emergency response information required in Subpart G of Part 172, measures to protect the employee from the hazards associated with materials to which he may be exposed to in the workplace, and methods and procedures for avoiding accidents.

Note: A hazmat employee who repairs, modifies, reconditions, or test packagings as qualified for use in the transportation of hazardous materials, and who does not perform any other function subject to the regulations, does not have to receive safety training.

Security Awareness Training §172.704(a)(4)

Each hazmat employee must receive security awareness training. This training must include an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. A component covering how to recognize and respond to possible security threats must be included.

In-Depth Security Training §172.704(a)(5)

In addition to the above security awareness training, hazmat employees of employers that are required to have a security plan must receive in-depth security training on the security plan and its implementation. Hazmat employees who handle materials covered by the plan, perform a function related to the materials covered by the plan, or are responsible for implementing the plan must receive in-depth security training. In-depth security training must include company security objectives, organizational security structure, specific security procedures, specific security duties and responsibilities for each employee, and specific actions to be take in the event of a security breach.

For more information on security plans see Security Plans.

Note: A railroad maintenance-of-way employee or railroad signalman who does not perform any function subject to the regulations, does not have to receive security awareness or in-depth security training.

Modal-Specific Training §172.700(c); §177.816

In addition to the above training, each mode of transport (highway, rail, air, or water) has additional training requirements. For example, by highway, driver training is required for a hazmat employee who drives a vehicle transporting hazardous materials. The driver must be trained on the safe operation of the motor vehicle and the applicable requirements of the Federal Motor Carrier Safety Regulations. See Driver Training for more information on this topic.

Training Timetables §172.702(b); §172.704(c)

Training for an employee must be completed before the employee performs any function subject to the Hazardous Materials Regulations. However, an employee may perform hazmat job functions before completing training, provided:

·    the employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee; and

·    the hazmat training is completed within 90 days of employment or change in job function.

Each hazmat employer must train, test and certify each hazmat employee at least once every three years.

However, if a new regulation is adopted or an existing regulation is changed, that relates to a function performed by a hazmat employee, that employee must be instructed on the new or revised regulations. This training must be completed before the employee performs the function and before the employee’s three year recurrent training. The employee only needs to be instructed on the new or revised requirements. Testing and record keeping for the new or revised requirements is not required until the employee’s three year recurrent training.

For in-depth security training, if the security plan is revised during the three-year recurrent training cycle, the hazmat employee must be trained within 90 days of implementation of the revised security plan.

Transferability of Other Employment Training §172.704(c)(3)

Relevant training received from a previous employer or other source may be used to satisfy the training requirements, provided a current record of training is obtained from the hazmat employee's previous employer.

OSHA, EPA, or Other Security Training §172.704(b)

OSHA or EPA hazard communication training and security training required by other agencies that directly addresses training specified in these (DOT) regulations need not be duplicated. However, a word of caution: Different agencies define various hazards based on different criteria, and a definition or criteria that does not agree with the HMR cannot be substituted for the DOT definition or criteria.