Home > Help Center > Training Standards FAQs > Dangerous Goods (IATA, IMDG)

Dangerous Goods (IATA, IMDG)

Confused by the multiple training mandates for air and vessel shipping? Wondering why people call them international rules when they seem to be required for some shipments within the United States? Below are answers to some of the most frequent questions we receive about Dangerous Goods (IATA/IMDG) Training Standards.

Note that all U.S. and international shippers must also have DOT hazardous materials training (49 CFR). View the Hazmat (49 CFR) Training Standard FAQs.

Who needs IATA/IMDG training?
How often is retraining required?
I have heard that some IATA training takes two or three days. Why is the Lion course only one day?
If I have IATA and/or IMDG training, do I still need to attend DOT (49 CFR) training?
What must be included in IATA or IMDG training records?
How long do I have to keep my IATA and IMDG training records?
Who writes the IATA rules?
What is ICAO? And where does it fit in?
Who writes the IMDG Code?
Who enforces IATA and IMDG training?
Does IATA training need to be accredited or endorsed by IATA?
Is IATA training required if I am shipping by air within the United States?
Is IMDG training required if I am shipping by vessel within the United States?
Where can I get the IATA or IMDG rules?
What penalties might I face if I don’t have IATA or IMDG training?
How often do the IATA and IMDG rules change?

1. Who needs IATA/IMDG training?

The U.S. DOT requires training for all hazmat employees in the United States, regardless of the rules you are following to prepare hazardous materials for transportation. Hazmat employees must be trained on IATA or IMDG rules “to the extent such training addresses functions authorized by §§171.11 and 171.12.” [See 49 CFR 172.704(a)(2)(ii).] ssentially, if you choose to ship under international rules instead of 49 CFR rules, you must be trained on those rules.

In addition, IATA requires all persons concerned in the transport of dangerous goods by air to be trained according to IATA 1.5. The IATA training rules officially are recommendatory for all but aircraft operator employees. However, air carriers often require compliance with them as a condition of accepting your shipments.

The IMDG Code requires all persons concerned with the transport of dangerous goods to be trained according to IMDG 1.3. The IMDG training rules are recommendatory for shore-based personnel. However, vessel carriers often require compliance with them as a condition of accepting your shipments.

2. How often is retraining required?

Under 49 CFR 172.704(c)(2), all hazmat employee training must be repeated in its entirety at least every three years. If rules or an employee’s responsibilities change during that three-year period, the employee's training must be updated. The three-year retraining deadline is a deadline. Anyone not retrained by the third anniversary of his or her previous training may not legally perform any hazmat employee functions.

IATA requires recurrent training within 24 months of the initial training (IATA 1.5.0.3). Although this deadline is not legally enforceable, some air carriers may refuse your shipments if you have not received training within the previous 24 months.

IMDG rules defer retraining frequency to “a timeframe deemed appropriate by a competent authority” (IMDG 1.3.1.4). Therefore, the three-year DOT deadline applies in the U.S.

3. I have heard that some IATA training takes two or three days. Why is the Lion course only one day?

None of the hazardous materials regulations specify how long training must last. It simply must be enough to cover all requirements… applicable to the functions the employee performs. We don’t care to spend more time on training than necessary. We believe most industry professionals agree.

If you have no background in hazardous materials shipping, then learning the IATA rules probably requires more than one day. However, for someone already trained in U.S. domestic hazmat shipping rules at 49 CFR, we believe that IATA or IMDG rules are sufficiently similar to be learned in just one day of training.

Even if you ship only under international rules, you must still comply with a substantial part of the 49 CFR rules. Therefore, we recommend that you first attend the two-day Hazardous Materials Transportation Certification Workshop or have equivalent training. After that, you may obtain either your initial or recurrent training through the one-day IATA and IMDG workshops.

4. If I have IATA and/or IMDG training, do I still need to attend DOT (49 CFR) training?

Yes. If you are preparing hazardous materials for transportation according to the IATA or IMDG rules, there are still many DOT requirements in 49 CFR that your shipment must meet, as well as administrative and operational requirements that shippers must comply with, such as training and cargo security rules. At a minimum, you must be trained in these additional requirements.

The DOT allows hazardous materials to be shipped under IATA Dangerous Goods Regulations for any shipments traveling by air, provided the shipment complies with the additional DOT requirements listed at 49 CFR 171.11 and the shipper complies with all administrative rules in 49 CFR.

The DOT allows hazardous materials to be shipped under the IMDG Code for any shipments by vessel provided the shipment complies with the requirements listed at 49 CFR 171.12(b) and the shipper complies with all administrative rules in 49 CFR.

5. What must be included in IATA or IMDG training records?

All training records must include the following DOT-mandated elements:

The hazmat employee’s name;
The most recent training completion date of the hazmat employee’s training;
A description, copy, or the location of the training material;
The name and address of the person providing the training; and
Certification that the hazmat employee has been trained and tested, as required.

IATA training records must include the additional IATA-mandated elements:

“a copy of the certification received when the individual was trained, which shows that a test has been completed satisfactorily.”

IMDG rules do not require any additional training records but do specify that training records should be “made available to the employee if requested.”

6. How long do I have to keep my IATA and IMDG training records?

Neither IMDG nor IATA specifies record retention. However, under DOT rules [49 CFR 172.704(d)] a hazmat employer must keep all current records for each hazmat employee until 90 days after the employment ends. This includes records of IATA or IMDG training, if required.

7. Who writes the IATA rules?

IATA (the International Air Transport Association) is actually just a trade association of air carriers. However, the IATA Dangerous Goods Regulations incorporate all of the ICAO Technical Instructions and add requirements deemed appropriate by air carriers. Most air carriers will not accept hazmat shipments that do not meet these additional restrictions. Therefore, for practical purposes, IATA rules are the ones that air shippers must comply with.

8. What is ICAO? And where does it fit in?

The International Civil Aviation Organization, or ICAO, is an agency of the United Nations. It is charged with the responsibility to maintain the international rules for shipping dangerous goods by air. The ICAO Technical Instructions are based on the United Nations Committee of Experts recommendations and are updated every two years. These are the official international rules for hazmat air transportation. Compliance with the ICAO Technical Instructions is mandated under international treaty.

9. Who writes the IMDG Code?

The IMDG Code is produced by the International Maritime Organization (IMO), an agency of the United Nations charged with the responsibility to maintain the international rules for shipping dangerous goods by sea. The IMDG Code is based on the United Nations Committee of Experts recommendations. These are the official international rules for hazmat transportation by vessel. Compliance with the IMDG Code is mandated under international treaty.

10. Who enforces IATA and IMDG training?

The DOT enforces all hazmat transportation training in the United States. Although air and vessel carriers require training on international rules, where applicable, the U.S. DOT requires training and training records only to comply with 49 CFR training rules. However, in order to do business with many air or vessel carriers, you must comply with any stricter standards in the IATA or IMDG rules. Therefore, it is advisable to make sure that your IATA and IMDG training records meet all applicable standards.

11. Does IATA training need to be accredited or endorsed by IATA?

The International Air Transport Association accredits training programs for personnel directly involved with air transportation (e.g., airline employees or their agents). They do not accredit training for shippers or offerors of hazardous materials.

While the Federal Aviation Administration reviews training for aircraft operators, they do not do so for shippers’ training.

12. Is IATA training required if I am shipping by air within the United States?

The DOT allows you to ship hazardous materials under IATA rules if any part of a shipment is traveling by air, whether the shipment is international or domestic. If you choose to ship under IATA rules (or if your air carrier insists on this option), then you must be trained in those rules.

13. Is IMDG training required if I am shipping by vessel within the United States?

Similarly, the DOT allows you to ship hazardous materials under the IMDG Code if any part of a shipment is traveling by vessel, whether the shipment is international or domestic. If you choose to ship under IMDG rules (or if your vessel carrier insists on this option), then you must be trained in IMDG rules.

14. Where can I get the IATA or IMDG rules?

The IATA Dangerous Goods Regulations and the IMDG Code are copyrighted and can only be purchased from book retailers or IATA/IMO themselves. Students may purchase these books from Lion when registering for IATA and IMDG workshops.

15. What penalties might I face if I don’t have IATA or IMDG training?

Since the DOT is the enforcement authority in the United States, DOT penalties for violations apply. Civil penalties for violation of DOT regulations can be up to $32,500 per day, per incident. Criminal penalties can be as much as $250,000 per day, per incident, and five years in jail for individuals and $500,000 per day, per incident for organizations.

16. How often do the IATA and IMDG rules change?

The IATA rules are updated annually and the changes become effective January 1st each year. You must always follow the current edition of IATA rules.

IMDG rules are updated every two years. The rules are published in the latter part of each even numbered year. In the year following publication they become official, but you can still follow the earlier, two-year-old, rules. After one year, the updated rules become mandatory, until the next update is published. For example, on January 1, 2005, the 2004 edition of the IMDG Code became the official international rules, but you could still follow the 2002 edition. In 2006, you were required to follow 2004 rules—at least until the 2006 edition was released.

Calendar Year	2004	2005	2006	2007
Official IMDG Code Edition	2002	2004	2004	2006
Optional IMDG Code Edition	2004 (when issued)	2002	2006 (when issued)	2004

Caution: The U.S. DOT does not generally adopt the new international rule editions until January 1 of the year in which they become official. You may not use the new rules within the United States until they have been adopted by the DOT.

Site Map | Contact Us | Privacy Policy