DOT HAZMAT Training
A question for HAZMAT employers and employees……when was the last time you implemented and received U.S. Department of Transportation (DOT) Hazardous Materials training? If you find yourself wondering whether or not you have met compliance requirements with DOT training regulations, let’s go over some important information.
US DOT Hazardous Materials Regulation (HMR), 49 CFR 172.704- Subpart H, also known as HM -181, requires training for any individuals who handle, manage, transport, or ship hazardous materials or waste. This includes employees who load, unload, and handle hazardous materials; select, mark, label, or modify containers or packaging; prepare materials for shipping; prepare shipping papers; are responsible for the safety of hazardous materials during shipment; and vehicle operators.
Initial training: New HAZMAT employees or employees who change job functions must complete DOT training within 90 days. However, employees can perform new hazardous job materials functions prior to completing training if they are working under the supervision of a properly trained HAZMAT employee. Training must be carried out in accordance with the Hazardous Materials Regulation, and every person who performs a function related to the HMR must be trained and tested. All HAZMAT employees must also receive security awareness training. This widely utilized and recognized course is typically delivered within one day/eight hours and includes information on topics such as hazardous material tables, hazard classifications, placards, labels, hazardous waste manifests, security awareness, then concludes with knowledge testing. Learn more about completing DOT HAZMAT training online.
Recurrent training: All HAZMAT employees must undergo DOT training at least once every 3 years. It is important to point out that the entire course must be completed in full every three years. Currently, there is no shorter refresher course that meets the requirement.
Recordkeeping: An often-overlooked area of training compliance is the maintenance and availability of training records as defined in Section 172.704(d). Each hazmat employer must create and retain a record of current training of each hazmat employee, inclusive of the preceding three years, for as long as that employee is employed by that employer as a hazmat employee and for 90 days thereafter. A hazmat employer must make a hazmat employee's record of current training available upon request, at a reasonable time and location, to an authorized official of the Department of Transportation or of an entity explicitly granted authority to enforce the HMR. The record must include:
(1) The hazmat employee's name;
(2) The most recent training completion date of the hazmat employee's training;
(3) A description, copy, or the location of the training materials used to meet the requirements in paragraph (a) of this section;
(4) The name and address of the person providing the training; and
(5) Certification that the hazmat employee has been trained and tested, as required by this subpart.
Access to an Electronic Code of Regulations for US DOT Title 49 can be found online.