Lion's office will be closed on Friday, July 4, in observance of Independence Day. For help with online training, please contact support@lion.com.
Search

Hazmat Housekeeping: Should I Keep the Training Test?

Posted on 3/10/2016 by Roger Marks

The US DOT’s hazmat training standard for “hazmat employees” includes a specific provision that requires employers to certify that the hazmat employee has been “trained and tested, as required by this subpart.” [49 CFR 172.704(d)(5)] To satisfy the “test” requirement, employees can take a written test, a performance test, or a web-based test. Hazmat employers often wonder: Is a copy of the test requried to prove to DOT that your employee has met the hazmat training standard?

The employers’ record of hazmat employee training must include the following elements:

  1. Employee name
  2. Most recent hazmat training completion date
  3. Description, copy, or location of training materials used to meet the requirements
  4. Name and address of the person providing the training
  5. Certification that the employee has been trained and tested in accordance with 49 CFR 172, Subpart H
[49 CFR 172.704(d)]

As for the test, employers may record employees’ completion of the hazmat test in a number of ways, provided that the requirements of §172.704(d) are satisfied:

  • Written certificate
  • Electronic computer file
  • Index card
  • Written documentation of tasks performed or answers given
  • Notebook entry
Should I Keep the Hazmat Test?

A common question for hazmat employers is whether the test itself should be kept as part of the employee’s hazmat training record.  If you look at the list of required elements of a hazmat training record above, you’ll notice that there is no reference to keeping a copy of the test taken.

In a 2010 letter of interpretation, PHMSA made it clear that the hazmat employer is not responsible for keeping a copy of the test.

hazmat training test

The HMR does require only that all hazmat employees are “trained and tested” and that employers keep records of training to ensure the employees are competent to prepare hazmat shipments.

Is the Certificate from My Trainer Enough?

A Certificate of Achievement received from a training provider may meet the requirements as a record of training. However, it is ultimately the employers’ responsibility to “certify” that hazmat employees have been trained in line with DOT standards. Employers should verify that the certificate provided includes each of the five elements above. If the certificate is missing any of these elements, the employer should add it or create a separate training record in order to meet the 49 CFR 172.704(d) requirements.

Nationwide Hazmat Workshops for Industry Pros

Build the expertise and confidence to ship hazmat safely and in compliance with the latest 49 CFR, IATA, and IMDG rules. The Complete Multimodal Hazmat Shipper Workshops are presented in convenient locations nationwide. Enroll now and get 365 days of complete on-the-job support, including access to the Finder Q&A service!

Join experienced hazmat professionals from your area for an engaging learning experience led by instructors who help uncover the real-world meaning of the regulations that affect your job.

Tags: DOT, hazmat shipping, training

Find a Post

Compliance Archives

Lion - Quotes

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

Hazmat Shipping Professional

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

Download Our Latest Whitepaper

Get to know the top 5 changes to OSHA’s revised GHS Hazard Communication Standard at 29 CFR 1910.1200 and how the updates impacts employee safety at your facility.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.