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Hazmat (49 CFR)

Not sure if you or your employees need training? Here are some of the most frequently asked questions we've received about the U.S. DOT training standard. Click here for a printable copy (.pdf) of DOT's training rule.

 If you need to train several hazmat employees, we can help determine what training they need.  If you need to train several hazmat employees, we can help determine a customized training program based on your employee job functions.

Shipping dangerous goods by air or vessel? Check the Dangerous Goods (IATA/IMDG) FAQs.

If you are dealing with hazardous waste, you may want to view the Hazardous Waste (40 CFR) FAQs.

  1. To whom do the Department of Transportation (DOT) training rules apply?
  2. Who must be trained?
  3. What training is required?
  4. How often must training be given?
  5. But I don't ship much that's "hazardous"...
  6. How does DOT training relate to training required by EPA or OSHA?
  7. What training does Lion provide?
  8. Should I take a web-based course or attend a public workshop?
  9. Which course or workshop is for me?
  10. If I get trained by Lion will I be "certified"?
  11. If I get trained by Lion, can I train others?
  12. What about international rules
  13. Important regulatory references on training
1. To whom do the Department of Transportation (DOT) training rules apply?

U.S. DOT "hazmat employee" training rules apply to any company which performs any function in any way regulated by the U.S. DOT Hazardous Materials Regulations (HMR). This includes any company which:

  • Offers hazardous material for transportation
  • Packages, marks, or labels hazardous material for transportation
  • Loads or unloads hazardous materials transport vehicles
  • Transports hazardous material
  • Receives and forwards packages containing hazardous materials
  • Manufactures packaging for use in transporting hazardous materials
  • Tests hazardous material packaging

There are no exemptions provided for small companies. Even a self-employed person who ships hazardous materials as part of his job must provide training for himself.

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2. Who must be trained?

Each "hazmat employer" is required to train each of his or her "hazmat employees." Hazmat employee is defined as any employee "...who in the course of employment directly affects hazardous materials transportation safety." A brief list of employees who are likely to fit that definition includes anyone who:

  • Classifies materials (analyzes or researches literature)
  • Determines ORM-D status
  • Determines if a material is an infectious waste, hazardous waste, or hazardous substance (determines RQs)
  • Assigns packing groups or hazard zones
  • Identifies vapor pressures, specific gravities, viscosities, or other properties
  • Determines emergency response information to be included with shipping papers, including determining when shipping papers or emergency response information may not be necessary
  • Is involved in selecting shipping descriptions
  • Designs, selects, purchases, or fills packages
  • Determines which packages are compatible or meet the prescribed standards
  • Determines if a package can be reused, if a package is empty, or if a package needs reconditioning (tank cars, cargo tanks, drums, etc.)
  • Determines any markings to be applied to a package
  • Determines which labels and how many must be applied to the package, including determining when labeling may not be necessary
  • Determines how many of which placards are required, provides placards, and affixes placards
  • Determines what should appear on shipping papers or actually fills out shipping papers
  • Selects carriers or modes of transportation to be used
  • Loads, unloads, moves, handles, or works around hazardous materials (warehouses, loading docks)
  • Responds to damaged containers, spills, or leaks and reports incidents
  • Operates any vehicle or equipment used to transport hazardous materials

and SUPERVISORS of those performing any of the above activities.

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3. What training is required?

Details of training required per job function are determined by the hazmat employer. The DOT does, however, require certain categories of training.

  1. General Awareness Training: At a minimum, all hazmat employees must be given a general understanding of the entire hazardous materials transportation program, so that they know how their jobs fit into the system.
  2. Function-Specific Training: Each employee (by job function) also must be trained on any requirements that he or she must meet in performing transportation-related duties.
  3. Safety Training: Persons handling or potentially exposed to hazardous materials during the cycle of transportation (e.g., drivers, loaders, loading dock workers, warehousemen, etc.) must be trained in safe handling and emergency response procedures applicable to the hazards to which they may be exposed.
  4. Security Awareness Training: Each hazmat employee must be trained to recognize and protect against potential terrorist threats involving hazardous material shipments.
  5. Security Plan Training: For operations that require a written security plan, each hazmat employee must also be trained in company security objectives, organizational structure and specific procedures, responsibilities or actions required from them.
  6. Driver Training: In addition, specific requirements for training of hazardous materials drivers are found at 49 CFR Part 177 and Parts 350-399.

The first five categories are generally referred to as "hazmat employee" training.

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4. How often must training be updated or repeated?

Hazmat employee training must be updated any time DOT issues any new or revised rule applicable to the duties of a particular employee [49 CFR 172.702(b)]. The training must be completed by each employee "prior to performance of a function affected by the new or revised rule" [61 FR 27169, May 30, 1996]. Because most rules have a delayed effective date or a transition period for compliance, Lion believes that annual update training will meet the needs of most HMT compliance managers or supervisors. Managers will then need to determine what updates affect which groups of hazmat employees in their operations.

Hazmat employee training must be repeated in its entirety (not just updated or refreshed) at least every three years [49 CFR 172.704(c)(2)]. This "recurrent" training must include testing and formal recordkeeping. If an employee has not been re-trained within the past three years, that employee cannot perform any hazmat employee functions until trained.

Also, 49 CFR 173.1 requires the offeror of a hazardous material to instruct each person involved in preparing and offering the package in applicable DOT rules, regardless of whether the person is an employee or not.

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5. But I don't ship much that's "hazardous"...

There are no exceptions provided for minor involvement in hazardous materials transportation. If you ever ship any hazardous materials, you must be trained. Of course, the scope of training required may be less for hazmat employees who only make occasional hazardous materials shipments or only ship one or two specific hazardous materials. Complete records must be kept on all training, in accordance with DOT rules [49 CFR 172.704(d)].

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6. How does DOT training relate to training required by EPA or OSHA?

The U.S. Environmental Protection Agency (EPA) requires training for persons managing hazardous wastes at waste generator or treatment, storage, and disposal facilities (TSDFs).

The Occupational Safety and Health Administration (OSHA) has two general chemical hazard training rules. The Hazard Communication Standard (sometimes referred to as "employees' right to know") requires general workplace chemical hazard training as well as chemical labeling and material safety data sheets. The Hazardous Waste Operations Standard (HWOS or HAZWOPER) requires specific training for persons involved in site cleanup, permitted TSDF operations, or chemical emergency response outside their ordinary workplace.

DOT, EPA, and OSHA requirements are distinct and separate. It is generally good management practice to combine training into a single session where agency requirements are similar. However, you must assure that you comply with each rule individually.

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7. What training does Lion provide?

Lion Technology offers a suite of hazmat transportation training designed to meet all of your training needs.

Lion presents regularly scheduled, open enrollment, public training workshops across the United States all year long. These workshops cover EPA, DOT, and OSHA regulations. In the area of DOT hazardous materials transportation, our "Hazardous Materials Transportation Certification" workshop is presented approximately 60 times per year.

Web-based training courses are also available via the Lion Institute web site, 24 hours a day. For a listing of currently available web-based courses, visit our web-based training course catalog.

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8. Should I take a web-based course or attend a public workshop?

The choice between attending a public workshop versus taking an on line training course is a personal decision. You should consider the following:

  • What is your style of learning?
    • If you like classroom-style, live, instructor-led training where you can talk face to face with your neighbor or with the instructor during the breaks, and work on exercises with others, Lion's public workshops offer all of these.
    • If you prefer to work at your own pace, have the option to review the information you've learned as many times as you need to, work on exercises when you feel you're ready, and still have e-mail dialog with an instructor and fellow students, web-based training courses provide this approach to learning.
  • How much time do you have?
    • If you'd like to get out of the office for two days, get your training all at once and head back to work with a bunch of fresh ideas and tools to apply to your job, the public workshops are for you.
    • If you find that you can't afford to take two full days away from the office, or just prefer to get your training in increments, applying the information as you learn, Lion's web-based training courses are divided into brief, focused lessons.
  • When do you need training?
    • Lion presents over 200 workshops per year, nationwide, so chances are one will come to a major metropolitan area convenient to you during the year. Some workshops are presented in key cities more than once per year! If you've decided to attend a public workshop, you can plan to attend the one most convenient to you, or if you need it sooner, travel to a nearby city and get a discounted rate at the hotel where the workshop will be held.
    • If you want access to training immediately and whenever you need it, without traveling, Lion's web-based training courses are available 24 hours a day via the Internet.

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9. Which course or workshop is for me?

If you have overall responsibility for the preparation and offering of hazardous materials, and you've decided that you prefer to attend a two-day, classroom-style training workshop, Lion's nationally-known "Hazardous Materials Transportation Certification" workshop is for you. This workshop teaches you Lion's "Ten Steps" to hazardous materials transportation, providing you with a systematic approach to navigating the myriad of requirements in DOT's hazardous materials regulations. You'll learn the "big picture" of hazardous materials transportation, security issues that you should be concerned about, as well as detailed instruction on classifying, naming, packaging, marking, labeling, placarding, and loading hazardous materials.

If you are looking for focused, function-specific training, or you've decided you prefer web-based training, Lion has web-based training modules covering all aspects of preparing hazardous materials for transportation. Which course or courses are appropriate depends on your specific job functions. To find out more about which Lion web-based training is right for you, feel free to call or e-mail our friendly customer service representatives at 888-546-6511.

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10. If I am trained by Lion, will I be "certified"?

The U.S. DOT does not require "certification" or "licensing" of hazardous materials shippers in the way that a person may be licensed to practice plumbing, be registered as a professional engineer, be certified as an accountant, or be licensed to drive a vehicle. There is a nationwide program of commercial drivers licensing, administered by states, that includes licensing for drivers of vehicles carrying hazardous materials, but this is in addition to hazmat employee training.

The DOT does require that any hazmat employee training must include:

  • Testing of each individual (written, oral, by demonstration, or otherwise) to assure that the person was trained; and
  • Certification by the employer, in a "record of training" kept in the employer's files, that the employee was trained, tested, and passed the test.

To assist in complying with DOT's training requirements, all Lion workshops and web-based training courses include exercises throughout the program and quizzes at completion. Upon passing the test, each student receives a Certificate of Achievement from Lion Technology, documenting that the person was trained and tested. The Lion certificate may be used by the employer as part of the required "record of training."

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11. If I am trained by Lion, can I train others?

DOT's training standard does not impose any specific requirements for qualification of trainers. DOT does not "approve," "certify," or otherwise accredit hazardous materials transportation trainers or training programs.

All of Lion's training products and services are designed to train you in regulatory requirements for management of hazardous materials. While our courses and workshops are not designed to teach you how to be a trainer, you will learn what you need to teach your personnel.

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12. What about international rules?

When shipping hazardous materials within or from the U.S. via air or water, shipments may comply with international (IATA/ICAO or IMDG) rules. Such shipments still must comply with certain portions of 49 CFR and the shippers must be trained in those additional U.S. DOT requirements (Ref. 49 CFR 171.11–12a]. The rules of IATA (the International Air Transport Association), ICAO (the International Civil Aviation Organization), and IMO (the International Maritime Organization) each have their own training requirements. These are in addition to U.S. DOT-required training.

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13. Important regulatory references on training
  • 49 CFR 172, Subpart H
  • 49 CFR 171.8, definitions of "hazmat employer" and "hazmat employee."
Hazardous Materials Transportation Training Extracts
172.702 Applicability and responsibility for training
Who Is Responsible for Training?
(a) A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart.
When to Train

(c) Initial and recurrent training.

(1) Initial training. A new hazmat employee, or a hazmat employee who changes job functions may perform those functions prior to the completion of training provided.

   (i)The employee performs those functions under the direct supervision of a properly trained and knowledgeable hazmat employee; and

   (ii) The training is completed within 90 days after employment or change in job function.
Recurrent Training
(2) Recurrent training. A hazmat employee shall receive the training required by this subpart at least once every three years.

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