Hazmat Housekeeping: Should I Keep the Training Test?
The employers’ record of hazmat employee training must include the following elements:
- Employee name
- Most recent hazmat training completion date
- Description, copy, or location of training materials used to meet the requirements
- Name and address of the person providing the training
- Certification that the employee has been trained and tested in accordance with 49 CFR 172, Subpart H
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
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.
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.
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