What is the DOT?
DOT HAZMAT Training Requirements
We hear the acronym DOT referenced often, especially when it comes to the handling and transportation of hazardous materials. Let’s explore just what, and who, the DOT is.
DOT stands for the U.S. Department of Transportation. The DOT was established by an act of Congress on October 15, 1966 and began operating April 1, 1967. According to the DOT's website, its official mission statement is “To deliver the world’s leading transportation system, serving the American people and economy through the safe, efficient, sustainable, and equitable movement of people and goods.”
The DOT is one of the largest and most complex federal entities with numerous administrations operating within it, including:
- The Federal Aviation Administration (FAA)
- The Federal Highway Administration (FHWA)
- The Federal Motor Carrier Safety Administration (FMCSA)
- The Federal Railroad Administration (FRA)
- The Federal Transit Administration (FTA)
- The Great Lakes Saint Lawrence Seaway Development Corporation (GLS)
- The Maritime Administration (MARAD)
- The National Highway Traffic Safety Administration (NHTSA)
- The Office of Inspector General (OIG)
- The Office of the Secretary (OST)
- The Pipeline and Hazardous Materials Safety Administration (PHMSA)
The Pipeline and Hazardous Materials Safety Administration (PHMSA) regulates and ensures the safe and secure movement of hazardous materials by all modes of transportation, including pipelines. To minimize threats to life, property, or the environment due to hazardous materials related incidents, PHMSA's Office of Hazardous Materials Safety develops regulations and standards for the classifying, handling, and packaging of over 1 million daily shipments of hazardous materials within the United States. Applicable regulations can be found online with specific reference to Title 49, Parts 100-185.
PHMSA’s Hazardous Materials Regulation (HMR), 49 CFR 172.704- Subpart H, also known as HM-181, requires training for anyone who handles, manages, transports, or ships hazardous materials or waste. Hazardous materials include chemicals, toxins, and pollutants. They also include any hazardous substances and hazardous wastes as defined by the U.S. Environmental Protection Agency (EPA), as well as materials that are sensitive to shock or temperature.
Who needs HM-181 training?
DOT HAZMAT Training, HM-181, applies to any employee who:
- Loads, unloads, or handles hazardous materials or hazardous waste.
- Manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packages as qualified for use in the transportation of hazardous materials or hazardous waste.
- Prepares any hazardous materials or hazardous waste for transportation.
- Is responsible for the safety of transporting hazardous materials or hazardous waste.
- Operates a vehicle used in the transportation of hazardous materials or hazardous waste.
Initial DOT Training Requirements
New HAZMAT employees or employees who change job functions must complete DOT HAZAMT training within 90 days. However, employees can perform new hazardous job materials functions prior to completing DOT HAZMAT training if they are working under the supervision of a properly trained HAZMAT employee. Training must be carried out in accordance with the HMR, and every person who performs a function related to the HMR must be trained and tested.
The DOT training course is typically delivered within one day (eight hours), covers information on topics shown below, and concludes with knowledge testing.
49 CFR Section 172.704 states that HAZMAT training shall include:
- General awareness/familiarization training — Provides familiarity with the general DOT training requirements of the Hazardous Materials regulations (HMR) and enables the employee to recognize and identify hazardous materials. This DOT training will provide a basic understanding of:
- Identification of hazardous materials
- Hazard classification system
- Hazardous materials table
- Markings and labels
- Shipping papers
- Understanding of HMR training requirements
- Requirements for incident reporting
- Function-specific training — Provides a detailed explanation of HMR requirements to be adhered to and performed by the employee. Training will differ according to the employee’s responsibilities and company needs.
- Safety training — Covers the dangers presented by the handling of hazardous materials, the emergency response to hazardous materials, and accident avoidance.
- Security awareness training — Addresses the security risks involved with the transportation of hazardous materials and discusses the methods of recognizing and responding to potential security threats.
- In-depth security training — Outlines a company’s security plan including security objectives, procedures, employee responsibilities, actions to take in the event of a security breach, and the company’s security structure. This training is only necessary for employees who may handle or perform regulated functions related to the transportation of materials covered by the security plan or who may be responsible for implementing the company security plan.
All HAZMAT employees must undergo DOT HAZMAT 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 duration refresher course that meets the DOT training requirements.