When it comes to training and re-training hazmat employees—timing is everything. When is hazmat training
required, how often, and how long?
When you hire a new hazmat employee or reassign an existing employee to a hazmat-related job role, the training clock starts ticking. Every new hazmat employee must complete initial hazmat training within 90 days of hire or reassignment.
Hazmat employees are permitted to work during these 90 days, but only under direct supervision of an appropriately trained person (See 49 CFR 172.704).
Re-Training Hazmat Employees on Schedule
Once initial training is complete, another
clock starts ticking. US and international regulations also require recurrent hazmat training
for all employees who affect the safety of hazardous materials in transport.
US DOT requires recurrent hazmat training once every three years
(49 CFR 172.704).
If you ship hazmat by ground only, that’s the only re-training deadline you need to know.
But if you use the International Air Transport Association Dangerous Goods Regulations
(IATA DGR) to ship hazmat by air, you may have noticed that IATA requires training every 24 months
(IATA DGR 18.104.22.168).
Every 2 Years or Every 3 Years?
So, the question is: Do we follow US DOT’s three-year training rule or the IATA DGR’s two-year training rule?
Here’s the answer: Nearly all
of the world’s airlines are members of IATA, including the major air cargo movers like FedEx and UPS. To ship hazardous materials (i.e., “dangerous goods” or DG) using an IATA airline, you must fully comply with the IATA DGR requirements.
That includes training hazmat employees
once every 24 months
to ensure they maintain their competencies.
Questions about hazmat training? Lion’s Hazmat Training FAQ has answers.
Practical Answer vs. Legal Answer
So, while US law requires hazmat training once every three years, training employees every two years is the practical answer for hazmat air shippers
that want to offer shipments to major air carriers.
Failure to train hazmat employees on IATA's two-year schedule invites a critical consequence: IATA airlines won’t accept your shipments.
How Many Hazmat Training Hours Are Required?
Unlike some other regulatory training standards (e.g., OSHA HAZWOPER
) the US and international hazmat training rules do not specify a minimum number of hours for hazmat training.
While they don’t tell us exactly how long employees’ training should take, both 49 CFR and the IATA DGR lay out critical elements that all hazmat training must cover.
Both US DOT and IATA require training on the following topics:
- General awareness/familiarization training,
- Security awareness training,
- Function-specific training,
- Safety training*, and
- Training on the site's cargo security plan (when applicable)**
*Safety training is required to employees who handle, work with,or may be exposed to hazardous materials.
**If the site has a written cargo security plan, employees will need “in-depth security training” that informs them of the security plan elements that affect their jobs.
[See 49 CFR 172.704 and IATA DGR 1.5 & 1.7.2]
For employees who prepare hazmat air shipments, all applicable training elements must be covered during initial hazmat training and once every 24 months
thereafter to maintain compliance with the IATA DGR.
If you ship hazmat by air and want a simple solution to this 3-year vs. 2-year training conundrum, you may find it easier and more efficient to provide full DOT and IATA hazmat training
to employees once every two years. This way, you don’t have to keep track of which employees need which elements of training (49 CFR, IATA, or both) in any given year.
Plus, if you need to rush ship a package by air, you can be confident that your hazmat training is up to date.
Stay on Schedule with On-demand Hazmat Courses
, find on-demand online courses to help you satisfy US DOT and IATA DGR training requirements for new or experienced hazmat employees.
Hazmat Ground Shipper Certification (DOT)
Develop a step-by-step process to navigate and apply the 49 CFR Hazardous Materials Regulations (HMR) to your shipments. This comprehensive, self-paced online course is built to help satisfy DOT's training mandate for new hazmat employees at 49 CFR 172.704.
Recurrent Hazmat Ground Shipper Certification (DOT)
Streamlined 49 CFR hazmat training course to refresh employees’ expertise and help meet DOT’s recurrent training mandate.
IATA Hazmat Air Shipper Certification
This course covers the additional, unique requirements that shippers must know to offer hazardous materials for transport by cargo or passenger aircraft in compliance with the current edition of the IATA DGR.
Shipping Employee Courses:
Shipping Hazmat by Ground—Ops
Shipping Hazmat by Air—Ops