Hazmat Training for Ground Shippers

The US DOT requires hazmat employee training to cover all applicable modal requirements. If you ship hazmat/dangerous goods by ground, you need to comply with the Hazardous Materials Regulations found in Chapter 49 of the Code of Federal Regulations (49 CFR).

49 CFR Initial Training Requirements

Hazmat employees need training within 90 days of employment or change in job function. During those 90 days, these hazmat employees may perform covered work only if directly supervised by a properly trained and knowledgeable hazmat employee [49 CFR 172.704(c)(1)].

If there is no supervisor, hazmat employees need to be trained immediately and may not perform covered functions until training is complete.

How Often Is Ground Shipper Training Required?

Under the DOT’s rules, all hazmat employee training must be repeated in its entirety at least every three years. Update training is required when regulations or an employee’s responsibilities change. Anyone not retrained by the third anniversary of their previous training may not legally perform any hazmat employee functions [49 CFR 172.704(c)(2)].

What Must Be Included in the DOT Hazmat Training Records?

The DOT hazmat employee training standard requires the hazmat employer to prepare and retain a record of training for each employee. The record must contain the following information:

• The hazmat employee’s name.
• The most recent training completion date.
• A description, copy, or location of the training materials used.
• The name and address of the person performing the training.
• A certification by the hazmat employer that the hazmat employee has been trained and tested.

How Long to Keep DOT Hazmat Training Records

Under the DOT’s rules, a hazmat employer must keep all current training 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.

Who Enforces DOT Hazmat Training Mandates?

The US DOT Pipeline and Hazardous Materials Safety Association (PHMSA) enforces all 49 CFR regulations, including training mandates. For hazmat training violations, the minimum fine is more than $600 per employee. And, when the violation is a continuing one, each day of the violation constitutes a separate offense [49 CFR 107.329(a)].

PHMSA officials investigate sites for a variety of reasons, including complaints, reinspection of previously out-of-compliance sites, and hazmat incidents. If an inspector comes to your facility and finds hazmat employees without adequate training, you will be cited for the number of employees times the number of days without training. Each of those cited violations will carry at least the minimum fine for hazmat training violations.

Tags: 49 CFR, hazardous materials, hazardous materials regulations, hazmat shipping