Is Hazmat Training Mandatory for Forklift Drivers?

In a recent free livestream presentation, “DOT Hazmat Training Basics for Shippers,” Lion instructor Joel Gregier, CDGP addressed a common question about hazmat employee training for forklift drivers/operators: Does US DOT require hazmat training for forklift drivers who move hazmat packages or containers? 

The short answer is that for forklift drivers who load or unload hazmat on to or off a vehicle, yes—hazmat employee training is required by the Hazardous Materials Regulations (HMR).  

The Hazmat “Cycle of Transportation” 

As Joel explained during the livestream, hazardous materials are subject to regulation while they are in the “cycle of transportation.” This cycle of transportation includes loading hazmat onto a vehicle, unloading hazmat from a vehicle, and transferring hazmat from one vehicle to another. 

"Loading, blocking, and bracing a hazardous materials package in a freight container or transport vehicle" is listed as one of many pre-transportation functions covered by the HMR and defined at 49 CFR 171.8. The regulations refer to the placement of hazardous materials onto a vehicle for transportation as loading incidental to movement. 

Hazmat and “Loading Incidental to Movement” 

In a 2022 letter of interpretation, US DOT confirms that hazmat training is required to load or unload hazmat from a vehicle. In the letter, PHMSA responds to a cargo services company who asked for clarification about the hazmat training requirements for forklift drivers. 

In this situation, the driver’s responsibilities include unloading hazmat from a truck and transferring it into another vehicle (an aircraft).

PHMSA sets up the situation this way in the letter: 

“…You state that a forklift operator's duties are limited to removing hazardous material cargo from a truck and placing that cargo onto an aircraft's cargo hold floor… (You) believe the forklift operator is not a hazmat employee as defined in §171.8 and therefore, not subject to hazardous materials training…”

PHMSA Letter of Interpretation 22-0066. 11/22/22. PHMSA.gov

PHMSA goes on to explain why, in this situation, the forklift driver(s) must have hazmat training: 

"Your understanding is incorrect. A hazmat employee includes an individual employed on a full-time, part-time, or temporary basis by a hazmat employer, who directly affects hazardous materials transportation safety and who—during the course of employment—loads, unloads, or handles hazardous materials (see §171.8)…

Since the forklift operator is handling hazardous material cargo by moving it from the truck and placing it onto the aircraft, this would be considered loading incidental to movement, which is a covered hazardous materials function that would make a person subject to hazmat training requirements as prescribed in §172.704 of the HMR.” 

Ibid

On the other hand, forklift drivers who do not load or unload vehicles, and who only move hazmat from place to place within the facility or property, would not need hazmat training to perform this job role.

Hazmat training could be required depending on the forklift drivers' other responsibilities—e.g., packaging hazmat, affixing markings and labels, filling out shipping papers. But because moving packages within the facility is not considered part of the "cycle of transportation," hazmat training is not required for this specific job task. 

Hazmat Training to Load Vehicles

Lion's Hazmat Loading Dock Worker Online Course provides DOT hazmat training required for hazmat employees who load or unload hazardous materials to or from motor vehicles, segregate materials in a vehicle, and/or offer placards for hazmat ground shipments. 

This online hazmat course provides general awareness, security awareness, and function-specific training required for "hazmat employees," including forklift drivers who load or unload vehicles. US DOT requires employers to provide hazmat training upon initial hiring and at least every 3 years thereafter for all hazmat employees (49 CFR 172.704).

Tags: forklift, hazmat training, PIT