Hazmat Training: A Complete Guide for Shippers of Hazardous Materials

In 1970, Congress passed the Hazardous Materials Transportation Act, establishing the Federal framework governing how hazardous materials (hazmat) are shipped in the US. This act also established training requirements for every person who directly affects hazmat transportation safety. Exactly what employees need to know and what training they need depends on their role and responsibilities and how the hazmat packages they impact get to their destination.

This guide clarifies hazmat shipper training requirements for shippers based in the US that ship by ground, air, or sea—or some combination of the three.

Who Needs Hazmat Shipper Training?

In the United States, the US Department of Transportation requires each “hazmat employer” to train each “hazmat employee.” A hazmat employee is anyone who, in the course of employment, directly affects hazardous materials transportation safety. A hazmat employer is anyone who employs a hazmat employee. Anyone who supervises a hazmat employee is also a hazmat employee.

• More details: Hazmat Training for Ground Shippers

The International Air Transport Association (IATA) requires training for all personnel who transport dangerous goods, according to IATA DGR 1.5. The IATA training requirements are technically only recommendatory for all but aircraft operator employees. However, most air carriers require compliance with the IATA Dangerous Goods Regulations as a condition of accepting air shipments.

• More details: Hazmat Training for Air Shippers

The International Maritime Organization (IMO) requires IMDG Code training for all personnel who transport dangerous goods, according to IMDG Code 1.3. The IMDG Code’s training requirements are technically only recommendatory for shore-based personnel. However, vessel carriers often require compliance with them as a condition of accepting dangerous goods shipments.

• More details: Hazmat Training for Vessel Shippers

What Job Functions Likely Fit This Definition?

A brief list of employees who are likely to fit the above definition of “hazmat employee” includes anyone who:

• Classifies hazardous materials (analyzes or researches literature).
• Reads or interprets hazardous materials regulations.
• Signs a hazmat shipping paper or hazardous waste manifest.
• Determines if a material is a hazardous waste or hazardous substance (determines RQs).
• Assigns packing groups or hazard zones.
• Is involved in selecting shipping descriptions.
• Designs, selects, purchases, or fills packages.
• Loads or unloads hazardous materials (e.g., warehouses or loading docks).
• Determines any markings or labels to be applied to a package.
• Determines if placards are required, provides placards, or affixes placards.
• Determines what should appear on shipping papers or actually fills out shipping papers.
• Determines emergency response information to be included with shipping papers.
• Selects carriers or modes of transportation to be used.
• Determines if a package can be reused, if a package is empty, or if a package needs reconditioning (e.g., tank cars, cargo tanks, and drums).
• Responds to damaged containers, spills, or leaks and reports incidents.
• Operates any vehicle or equipment used to transport hazardous materials.

What Is Hazmat Shipper Training?

Hazmat shipper training teaches shippers how to appropriately handle, prepare, and offer hazardous materials for shipment. Hazmat shipper training has five core elements, including relevance to each employee’s job function.

What Must Hazmat Shipper Training Actually Cover?

All hazmat employees must receive three kinds of training:

1. General awareness training.
2. Function-specific training.
3. Safety training.

Depending on the hazmat employee’s specific job functions, the employee may also need:

1. Safety training.
2. Security plan training.

How Often Is Hazmat Shipper Training Required?

The frequency of hazmat shipper training depends on how your hazmat packages travel.

Ground and vessel shippers must repeat training at least every three years. Air shippers must repeat training at least every 24 months.

In addition, a hazmat employee’s hazmat shipper training must be updated any time a rule changes that affects that employee’s job function. That update training must occur prior to “performance of a function affected by the new or revised rule” [61 FR 27169, May 30, 1996].

Update training must also be provided if an employee’s job duties change and those new duties are subject to DOT regulation.

Who Can Give Hazmat Shipper Training?

The US DOT’s training standard does not impose any specific requirements for qualification of trainers. The DOT does not “approve,” “certify,” or otherwise accredit hazardous materials transportation trainers or training programs.

For most air shippers of dangerous goods, IATA-accredited training is not required. Those who need accredited training include some airline employees, CNS Registered Agents, and other IATA-accredited cargo agents.

On several issues, including who can deliver training, the IMDG Code defers to each country’s “competent authority.” The competent authority in the US is the US DOT, and, therefore, the Department’s stance on the issue applies.

Can I Take Hazmat Shipper Training Online?

Yes. The US DOT recognizes online, computer-based, and virtual training programs as legitimate training modes. The hazmat employer must ensure that training, testing, recordkeeping, and certification requirements are met [49 CFR 172.702 and 172.704].

Tags: hazardous materials, hazmat shipping