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  • Writer's pictureFront Range Compliance

Requirements of HAZMAT Training

When it comes to Hazardous Materials (HAZMAT) Training, there are often questions about the requirements and frequency needed to keep you and your company in compliance. The official wording of the requirements can be found under Parts 172.704 and 177.816.

Hazmat Placards

Each and every HAZMAT employer must make sure that each of its hazmat employees is trained in accordance with the requirements defined in Parts 172.704 and 177.816. Each employee's training must be certified and tested, with current records retained to ensure the company's compliance. Proper HAZMAT training includes the following:

  • General awareness/familiarization

  • Function-specific

  • Safety

  • Security awareness

  • In-depth security training

  • Initial and recurrent training

  • Recordkeeping

  • Driver training

The general awareness and familiarization aspect of HAZMAT training is exactly what it seems, a general overview of what is required and to teach the employee how to recognize hazardous materials.


Function specific training is training gears specifically towards the functions the employee performs with the hazardous materials. If that function is driving, the employee will have specific driver training.


Safety training is the most common form of training across all aspects of the DOT, as everything that we train on revolves around safety. As for HAZMAT purposes, the safety aspect of training needs to include emergency response, protection from exposure and accident procedures. This also includes the required security training associated with HAZMAT, as every HAZMAT employee needs to understand the security risks associated with hazardous materials. 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 taken by each employee in the event of a security breach.The security training must be done within 90-days of employment.


Initial and recurrent training must be relevant and include compliance training. The initial aspect of training must be conducted when a new employee is hired or a current employee changes job function and must be completed within 90-days. Each HAZMAT employee must receive recurrent training at least every three years for the entirety of the subpart's regulations. Recurrent training must also be completed within 90-days of a revised security plan or changes to the company's HAZMAT policies.


Every HAZMAT employer must retain current training records for each employee and retain those documents throughout the employee's entire employment with the company. These records must be available upon request at a reasonable time to an authorized official. This file must be created within 90-days of their employment and must include the employee's name, most recent training and materials from that training, name and address of trainer, any and all certificates, and tests conducted in training.


All training must be relevant, current and in compliance with Parts 172.704 and 177.816. Training records must be retained for each HAZMAT employee for three years from the date of the last training, and for 90 days after the employee leaves.


The following terms are defined in section 171.8 of the HMR. They will help you better understand the HAZMAT transportation training requirements— particularly your responsibilities.


Definitions:

Training - a systematic program (consistent approach, testing, and documentation) that ensures a HAZMAT employee has knowledge of hazmat and the HMR, and can perform assigned HAZMAT functions properly. See §172.700 through §172.704.

HAZMAT employer - a person who uses one or more employees regarding:

  • Transporting hazmat in commerce

  • Causing hazmat to be transported or shipped in commerce

  • Designing, manufacturing, fabricating, inspecting, representing, marking, certifying, selling, offering, reconditioning, testing, repairing, or modifying packagings as qualified for use in the transportation of HAZMAT.

The term “HAZMAT employer” also includes any department, agency, or instrumentality of the United States, a State, a political subdivision of a State, or Native American Indian tribe engaged in offering or transporting HAZMAT in commerce. This term includes a person who is self-employed, including an owner-operator of a motor vehicle that transports HAZMAT in commerce.

HAZMAT employee - a person employed by a HAZMAT employer, or person who is self-employed, and who directly affects hazmat transportation safety including:

  • An owner-operator of a motor vehicle that transports HAZMAT

  • A person who does any of the following:

◊ Loads, unloads, or handles HAZMAT

◊ Designs, manufactures, fabricates, inspects, tests, reconditions, repairs,

modifies, marks, or otherwise represents packagings as qualified for use in the

transportation of HAZMAT

◊ Prepares HAZMAT for transportation

◊ Is responsible for safety of transporting HAZMAT

◊ Operates a vehicle used to transport HAZMAT


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Until then, make sure to check out our online DOT Training platform, DOT University! We currently are offering Reasonable Suspicion for Supervisors, Cargo Securement, Defensive Driving, and Pre/Post Trip Inspection. In the coming months, we plan on releasing DOT Compliance Essentials and Appendix A.


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