Who Needs Dangerous Goods Training?
If you ship hazmat by air or vessel, your carrier may require your packages to meet international standards, even if your shipment is not destined for another country. Most major air carriers require compliance with the International Aviation Transport Association Dangerous Goods Regulations (IATA DGR). Vessel shipments must comply with the International Maritime Dangerous Goods Code (IMDG Code). These rules apply in addition to the US DOT Hazardous Materials Regulations.
The DOT also requires hazmat employees to be trained on all applicable modal rules. Failure to comply with the IATA DGR or IMDG Code can result in civil penalties, rejected shipments, incidents in transit, and carrier blacklisting. See below for guidance on IATA and IMDG training mandates.
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Who needs IATA and/or IMDG training?
The US DOT requires training for all hazmat employees in the United States, regardless of the rules you are following to prepare hazardous materials for transportation. The US DOT allows shippers to follow the International Air Transport Association (IATA) Dangerous Goods Regulations and/or the International Maritime Dangerous Goods (IMDG) Code if part or all of the shipment is shipped by air or vessel. [49 CFR 171.24 and 171.25]
When following these rules, in addition to meeting the US DOT training standard, hazmat employees must also be trained on the IATA and/or IMDG rules “to the extent such training addresses functions authorized by 49 CFR Part 171 Subpart C.” Essentially, if US shippers choose to ship under the international rules, they must be in compliance and trained on applicable sections of 49 CFR as well as the IATA DGR and/or IMDG Code.
is required for all persons who transport dangerous goods according to IATA DGR 1.5. The IATA training rules officially are recommendatory for all but aircraft operator employees. However, most air carriers require compliance with the IATA DGR as a condition of accepting your shipments.
is required for all persons who transport dangerous goods according to IMDG Code 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.
How often is retraining required?
Under DOT rules, 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. Anyone not retrained by the third anniversary of his or her previous training may not legally perform any hazmat employee functions. [49 CFR 172.704(c)(2)]
IATA’s rules are a little more stringent than DOT’s. IATA requires recurrent training within 24 months of the initial training. [IATA 18.104.22.168] 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 competent authority.” In the US, the DOT is the competent authority, and therefore, the three-year DOT deadline applies to vessel shipments. [IMDG 22.214.171.124]
If I have IATA and/or IMDG training, do I still need to attend DOT (49 CFR) training?
Yes. If you are preparing dangerous goods 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 additional DOT requirements (listed at 49 CFR 171.22, 171.23, and 171.24) 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 additional DOT requirements (listed at 49 CFR 171.22, 171.23, and 171.25) and the shipper complies with all administrative rules in 49 CFR.
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What must be included in IATA or IMDG training records?
When shipping to or from the US, 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 materials used;
The name and address of the person providing the training; and
Certification by the hazmat employer that the hazmat employee has been trained and tested, as required.
IATA training records must include 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.”
How long do I have to keep my IATA and IMDG training records?
Neither IMDG nor IATA specifies record retention. However, under DOT rules, a hazmat employer must keep all current records for all hazmat employees for 90 days after their employment ends. In addition, training records dating back at least three years must be available upon request. This includes records of IATA or IMDG training, if required. [49 CFR 172.704(d)]
Who writes the IATA rules?
The International Air Transport Association (IATA) is actually just a trade association of air carriers that base their regulations on rules created by the International Civil Aviation Organization (ICAO). The IATA Dangerous Goods Regulations incorporate all of the ICAO Technical Instructions, but in addition, add extra requirements deemed appropriate by air carriers.
Most air carriers will not accept dangerous goods shipments that do not meet these additional restrictions. Therefore, for practical purposes, IATA rules are the ones that air shippers must comply with.
Who writes the IMDG Code?
The IMDG Code is produced by the International Maritime Organization (IMO), an agency of the United Nations charged with maintaining 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 dangerous goods transportation by vessel. Compliance with the IMDG Code is mandated under international treaty.
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 US 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 still comply with any stricter standards in the IATA or IMDG rules.
Does IATA training need to be accredited or endorsed by IATA?
No. The IATA Dangerous Goods Regulations do not require that training be provided by an accredited or endorsed training provider. [IATA DGR 1.5] The IATA Accredited Training Provider program is a voluntary program. There are certain persons who may require training from IATA accredited providers (e.g., certain airline employees, IATA Accredited Cargo Agents), but unless you fall into one of the additionally regulated entities, dangerous goods training may be received from non-IATA accredited schools.
It is possible that the US DOT Federal Aviation Administration may also have more specific requirements for training providers for aircraft operators, which are beyond IATA Dangerous Goods Regulations and DOT Hazardous Materials Regulations.
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What is a “dangerous good”?
Dangerous goods are “articles or substances which are capable of posing a risk to health, safety, property or the environment” and which are covered under the IATA and/or IMDG regulations. [IATA DGR Appendix A, IMDG 126.96.36.199]
Will training with Lion help me maintain my professional certifications?
Lion offers Continuing Education Units (CEUs), calculated based on training hours, which can be submitted for approval to help you maintain certification from organizations including: AHMP, ABIH, IHMM, NEHA, REHS, CCMP, and others.
While these groups typically do not pre-approve training programs that offer certification points, professionals can submit Lion CEUs for approval from their certifying organization.
Is the IATA Dangerous Goods Regulations manual required to complete air shipper training?
The IATA DGR is the main reference material used during Lion Technology’s IATA air shipper workshop, online course, and webinar. Lion designs air shipper training to help DG shipping managers and personnel navigate and use these rules on the job. We recommend that shipping facilities where dangerous goods are prepared for air transport according to the latest edition of the IATA DGR have at least one copy of the manual available on site to ensure employees have access to these rules.
Because the IATA DGR is a copyrighted publication, Lion Technology does not reproduce elements of this manual in our workshops, online courses, or webinars. A copy of the IATA DGR can be added during the registration process for any air shipper workshop, online course, or webinar.
Is the IMDG Code manual required to complete vessel shipper training?
The IMDG Code is the main reference material used during Lion Technology’s IMO vessel shipper workshop, online course, and webinar. Lion designs vessel shipper training to help DG shipping managers and personnel navigate and use these rules on the job. We recommend that shipping facilities where dangerous goods are prepared for vessel transport according to the latest edition of the IMDG Code have at least one copy of the manual available on site to ensure employees have access to these rules.
Because the IMDG Code is a copyrighted publication, Lion Technology does not reproduce elements of this manual in our workshops, online courses, or webinars. A copy of the IMDG Code can be added during the registration process for any vessel shipper workshop, online course, or webinar.