Who Needs Dangerous Goods Training?

The US DOT requires training for all hazmat employees in the United States, regardless of the rules you are following to prepare hazardous materials for transportation. The US DOT allows shippers to follow the International Air Transport Association (IATA) Dangerous Goods Regulations and/or the International Maritime Dangerous Goods (IMDG) Code if part or all of the shipment is shipped by air or vessel. [49 CFR 171.24 and 171.25]

When following these rules, in addition to meeting the US DOT training standard, hazmat employees must also be trained on the IATA and/or IMDG rules “to the extent such training addresses functions authorized by 49 CFR Part 171 Subpart C.” Essentially, if US shippers choose to ship under the international rules, they must be in compliance and trained on applicable sections of 49 CFR as well as the IATA DGR and/or IMDG Code.

IATA training is required for all persons who transport dangerous goods according to IATA DGR 1.5. The IATA training rules officially are recommendatory for all but aircraft operator employees. However, most air carriers require compliance with the IATA DGR as a condition of accepting your shipments.

IMDG training is required for all persons who transport dangerous goods according to IMDG Code 1.3. The IMDG training rules are recommendatory for shore-based personnel. However, vessel carriers often require compliance with them as a condition of accepting your shipments.

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

Hazmat air shippers must comply with stricter employee training rules. The IATA DGR requires recurrent training at least every 24 months [IATA 1.5.0.3] This deadline is not enforced by US DOT, the world's largest air carriers (i.e., IATA members) can refuse your dangerous goods shipments if you have not received training within the previous 24 months.

The IMDG Code rules for training defer “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 1.3.1.1]

Lion’s IATA DGR training is designed for hazardous materials/dangerous goods shipping personnel defined in IATA DGR Table 1.5.A, Categories 1, 2, 3, and 4:

1. Shippers (and persons undertaking the responsibilities of shippers’ , including operator staff acting as shippers, operator’s staff preparing dangerous goods as Company Materials (COMAT))
2. Packers
3. Staff of freight forwarders involved in processing dangerous goods
4. Staff of freight forwarders involved in processing cargo, mail, or stores (other than dangerous goods)

Our IATA DGR training is not intended for airline operator personnel, flight crew members or other crew members, passenger handling staff, airport security staff, or personnel who load aircraft (i.e., categories 5–12).  
 

Yes. If you are preparing dangerous goods for transportation according to the IATA or IMDG rules, 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 IATA Dangerous Goods Regulations for any shipments traveling by air, provided the shipment complies with additional DOT requirements (listed at 49 CFR 171.22, 171.23, and 171.24) and the shipper complies with all administrative rules in 49 CFR.

The DOT allows hazardous materials to be shipped under the IMDG Code for any shipments by vessel, provided the shipment complies with 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.

Find DOT Hazmat Shipper Training Now. 

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; and
5. Certification by the hazmat employer that the hazmat employee has been trained and tested, as required.

IATA training records must include additional IATA-mandated elements:

• “A copy of the certification received when the individual was trained, which shows that a test has been completed satisfactorily.”

IMDG rules do not require any additional training records but do specify that training records should be “made available to the employee if requested.”

Neither IMDG nor IATA specifies record retention. However, under 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 IATA or IMDG training, if required. [49 CFR 172.704(d)]

The International Air Transport Association (IATA) is a trade association of air carriers that base their regulations on rules created by the International Civil Aviation Organization (ICAO). The IATA Dangerous Goods Regulations (DGR) incorporate all of the ICAO Technical Instructions and add extra requirements deemed appropriate by air carriers.

Most air carriers will not accept dangerous goods shipments that do not meet these additional restrictions. Therefore, for practical purposes, IATA rules are the ones that air shippers must comply with.

Purchase the current edition of the IATA DGR here. 

The IMDG Code is produced by the International Maritime Organization (IMO), an agency of the United Nations charged with maintaining the international rules for shipping dangerous goods by sea. The IMDG Code is based on the United Nations Committee of Experts recommendations. These are the official international rules for dangerous goods transportation by vessel. Compliance with the IMDG Code is mandated under international treaty.

Purchase the current edition of the IMDG Code here. 

IATA DGR. IATA publishes a new edition of its Dangerous Goods Regulations (DGR) for hazardous materials air shippers every year. Each new edition takes effect on January 1 of the following year. 

Order the IATA DGR here.  

IMDG Code. The IMO publishes a new edition of its IMDG Code every other year. Each edition can be used for up to three years. In the first year following publication of a new IMDG Code, shippers may comply with the new edition or the previous one.

In the second year following publication, compliance with the latest edition is mandatory. 

Order the IMDG Code here. 

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

No. The IATA Dangerous Goods Regulations do not require that dangerous goods shipper training be provided by an accredited or endorsed training provider. [IATA DGR 1.5] The IATA Accredited Training Provider program is a voluntary program.

Certain persons may require training from IATA accredited providers (e.g., certain airline employees, CNS Registered Agents, or other IATA Accredited Cargo Agents). Unless you fall into one of the additionally regulated categories, dangerous goods training may be received from non-IATA accredited schools.

It is possible that the US DOT Federal Aviation Administration (FAA) may also have more specific requirements for training providers for aircraft operators, which are beyond IATA Dangerous Goods Regulations and DOT Hazardous Materials Regulations.

Find Training for Hazmat Ground, Air, and Vessel Shippers. 

Because US DOT is the enforcement authority in the United States, DOT penalties for violations apply. The maximum civil penalty for hazmat shipping violations is now about $90,000 per day, per violation. 

Training violations incur a minimum penalty of more than $500 per person, per day [49 CFR 107.329(a)].

Avoid civil penalties with expert IATA and IMDG dangerous goods shipper training. 

Lion offers nationwide workshops, live webinars, and 24/7 online courses to help you learn the international standards and meet IATA and IMO training mandates. In addition to expert training and support, students can purchase copies of the most recent IATA DGR or IMDG Code directly from Lion's bookstore.

Learn more about dangerous goods training options:

Hazardous Materials Air Shipper Certification
Hazardous Materials Vessel Shipper Certification

Dangerous goods are “articles or substances which are capable of posing a risk to health, safety, property or the environment” and which are covered under the IATA and/or IMDG regulations. [IATA DGR Appendix A, IMDG 1.1.2.1]

Lion offers Continuing Education Units (CEUs), calculated based on training hours, which can be submitted for approval to help you maintain certification from organizations including: AHMP, ABIH, IHMM, NEHA, REHS, CCMP, and others.

While these groups typically do not pre-approve training programs that offer certification points, professionals can submit Lion CEUs for approval from their certifying organization. 

The IATA DGR is the main reference material used during Lion Technology’s IATA air shipper workshop, online course, and webinar. Lion designs air shipper training to help DG shipping managers and personnel navigate and use these rules on the job. We recommend that shipping facilities where dangerous goods are prepared for air transport according to the latest edition of the IATA DGR have at least one copy of the manual available on site to ensure employees have access to these rules. 

Because the IATA DGR is a copyrighted publication, Lion Technology does not reproduce elements of this manual in our workshops, online courses, or webinars. A copy of the IATA DGR can be added during the registration process for any air shipper workshop, online course, or webinar.

Find IATA DG Air Shipper Training Now. 

The IMDG Code is the main reference material used during Lion Technology’s IMO vessel shipper workshop, online course, and webinar. Lion designs vessel shipper training to help DG shipping managers and personnel navigate and use these rules on the job.  We recommend that shipping facilities where dangerous goods are prepared for vessel transport according to the latest edition of the IMDG Code have at least one copy of the manual available on site to ensure employees have access to these rules.

Because the IMDG Code is a copyrighted publication, Lion Technology does not reproduce elements of this manual in our workshops, online courses, or webinars. A copy of the IMDG Code can be added during the registration process for any vessel shipper workshop, online course, or webinar. 
Find IMDG Vessel Shipper DG Training Now.

Yes. Shippers in the US must comply with US DOT’s hazmat employee training requirements, whether they follow DOT regulations or a complimentary international standard like the IATA Dangerous Goods Regulations (DGR). DOT’s regulations are consistent with what IATA calls “competency-based training,” though DOT does not use those exact words.

DOT requires all hazmat employees to receive function-specific training that addresses specific hazmat job functions or tasks (or “competencies”) that the employee will perform [49 CFR 172.704(a)(2)]. Lion’s IATA DGR courses for air shippers provide function-specific-training to help employers satisfy US and ICAO/IATA requirements, including the mandate that training be “competency-based.”

US DOT (49 CFR) and IATA regulations both allow employers to utilize third-party training providers, and both hold the employer responsible for certifying that each employee is adequately trained.

Lion IATA DGR training to ship dangerous goods by air:
Hazmat Air Shipper Certification (IATA)
Shipping Hazmat by Air (IATA)—Ops