Hazmat Training for Vessel Shippers

The US DOT requires hazmat employee training to cover all applicable modal requirements. If you ship hazmat/dangerous goods by vessel, you likely need to comply with the International Maritime Dangerous Goods (IMDG) Code.

IMDG Code Initial Training Requirements

Under the IMDG Code, personnel must be trained before performing covered work. Personnel may only perform functions for which they have not been trained under the supervision of a trained person [IMDG Code 1.3.1.1].

Learn about US DOT’s initial hazmat shipper training requirements here.

I Have IMDG Code Training. Do I Need DOT Training Too?

Yes. If you are preparing dangerous goods for transportation according to the IMDG Code, 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 the IMDG Code for any shipments by vessel, provided the shipment complies with the 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.

How Often Is Vessel Shipper Training Required?

The IMDG Code rules for training defer to “a competent authority” in each country. In the US, the DOT is the competent authority. Therefore, the three-year DOT training deadline applies to vessel shippers [IMDG Code 1.3.1.1].

What Must Be Included in IMDG Training Records?

When shipping to or from the US, all training records must include the following DOT-mandated elements:

1. The hazmat employee’s name.
2. The most recent training completion date of the hazmat employee’s training.
3. A description, copy, or the location of the training materials used.
4. The name and address of the person providing the training.
5. Certification by the hazmat employer that the hazmat employee has been trained and tested, as required.

How Long to Keep IMDG Code Training Records

The IMDG Code requires training records to be retained “as deemed appropriate by the competent authority” [IMDG Code 1.3.1.3]. As explained above, that competent authority is the DOT.

Under the 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 IMDG Code training, if required. [49 CFR 172.704(d)]

Who Enforces the IMDG Code Hazmat Training Mandates?

The DOT enforces all hazmat transportation training in the United States. Although vessel carriers require training on international rules, where applicable, the DOT requires training and training records only to comply with 49 CFR training rules. However, in order to do business with many vessel carriers, you must still comply with any stricter standards in the IMDG Code.

Tags: dangerous goods, hazardous materials, hazmat shipping, IMDG, IMDG Code