Who Needs Hazmat Training?

In the US, all hazmat shipments that leave your facility must comply with the US DOT Hazardous Materials Regulations (49 CFR). Training is mandatory for managers and employees who prepare hazmat for transport. The DOT hazmat rules are stringent. Penalties for non-compliance are as high as $81,993 per day, per violation. For hazmat training violations, the minimum fine is $493 per day, per violation. See below for guidance on DOT's training mandate or watch the Hazmat Training Video.
 

See Hazmat Training Options

 

What companies must follow the Department of Transportation (DOT) training rules?
US DOT “hazmat employee” training rules apply to any company with employees who perform any function in any way regulated by the US DOT Hazardous Materials Regulations (HMR). This includes any company with employees who:
  • Offer hazardous materials for transportation;
  • Package, mark, or label hazardous materials for transportation;
  • Load or unload hazardous materials transport vehicles;
  • Transport hazardous materials;
  • Receive and forward packages containing hazardous materials;
  • Manufacture packaging for use in transporting hazardous materials; and
  • Test hazardous material packaging.
There are no exemptions provided for small companies. Even self-employed people who ship hazardous materials as part of their job must provide training for themselves.
Who must be trained?
Each "hazmat employer" is required to train each of his or her "hazmat employees." A hazmat employee is anyone who, in the course of employment, directly affects hazardous materials transportation safety.

View the Hazmat Training Standard Video
 
A brief list of employees who are likely to fit that definition includes anyone who:
  • Classifies materials (analyzes or researches literature);
  • Signs a hazmat shipping paper or hazardous waste manifest; 
  • Determines if a material is a hazardous waste or hazardous substance (determines RQs);
  • Assigns packing groups or hazard zones;
  • Is involved in selecting shipping descriptions;
  • Designs, selects, purchases, or fills packages;
  • Loads, unloads, moves, handles, or works around hazardous materials (e.g., warehouses or loading docks);
  • Determines any markings or labels to be applied to a package;
  • Determines if placards are required, provides placards, or affixes placards;
  • Determines what should appear on shipping papers or actually fills out shipping papers;
  • Determines emergency response information to be included with shipping papers;
  • Selects carriers or modes of transportation to be used;
  • Determines if a package can be reused, if a package is empty, or if a package needs reconditioning (e.g., tank cars, cargo tanks, and drums);
  • Responds to damaged containers, spills, or leaks and reports incidents; and
  • Operates any vehicle or equipment used to transport hazardous materials.

Anyone who directly supervises those performing any of the above activities also needs to be trained. In addition, hazmat employers must also assure that anyone performing any regulated function on their behalf, such as a contractor, has been fully trained before they begin their work.

What training is required?
The hazmat employer determines the level and details of training based on an employee's job functions. The DOT does, however, require certain categories of training.
  1. General Awareness Training: At a minimum, all hazmat employees must be given a general understanding of the entire hazardous materials transportation program, so that they know how their jobs fit into the system.
  2. Function-specific Training: All hazmat employees must also be trained on any specific job functions that they perform in relation to the hazardous materials regulations.
  3. Safety Training: Persons handling or potentially exposed to hazardous materials during the cycle of transportation (e.g., drivers, loaders, loading dock workers, and warehousemen) must be trained in safe handling and emergency response procedures applicable to the hazards to which they may be exposed.
  4. Security Awareness Training: All hazmat employees must be trained to recognize and protect against potential terrorist threats involving hazardous material shipments.
  5. Security Plan Training: Each hazmat employee preparing or transporting certain high-risk shipments (as defined at 49 CFR 172.800(b)) must also be trained in company security objectives, organizational structure and specific procedures, and responsibilities or actions required from them.
  6. Driver Training: In addition, specific requirements for training of hazardous materials drivers are found at 49 CFR Part 177 and Parts 350-399.
The first five categories are generally referred to as "hazmat employee" training.

For more on who must be trained and what training is required to ship hazmat, view the Hazmat Training Standard Video. 
How often must training be updated or repeated?
Hazmat employee training must be repeated in its entirety (not just updated or refreshed) at least every three years. [49 CFR 172.704(c)(2)] This "recurrent" training must include testing and formal recordkeeping. If an employee has not been re-trained within the past three years, that employee cannot perform any hazmat employee functions until trained.

View the Hazmat Training Standard Video to learn more about the DOT's training requirements. 

In addition, hazmat employee training must be updated any time DOT issues any new or revised rule applicable to the duties of a particular employee. [49 CFR 172.702(b)] The training must be completed by each employee "prior to performance of a function affected by the new or revised rule." [61 FR 27169, May 30, 1996] Because most rules have a delayed effective date or a transition period for compliance, Lion believes that annual update training will meet the needs of most HMT compliance managers or supervisors. Managers will then need to determine what updates affect which groups of hazmat employees in their operations.

Finally, update training must also be provided if an employee's job duties change and those new duties are subject to DOT regulation. 
Do I need training if I only ship a very small amount of hazardous materials?
There are no exceptions provided for minor involvement in hazardous materials transportation. If you ever ship any hazardous materials, you must be trained. Of course, the scope of training required may be less for hazmat employees who only make occasional hazardous materials shipments or only ship one or two specific hazardous materials. Complete records must be kept on all training, in accordance with DOT rules. [49 CFR 172.704(d)]  Hazmat Training for Shipping Limited Quantities.
How does DOT training relate to training required by EPA or OSHA?
Many times, EPA hazardous wastes and OSHA hazardous chemicals will also meet the definition of a DOT hazardous material, and companies will need training on applicable rules. DOT, EPA, and OSHA requirements are distinct and separate, but it can be a good management practice to combine training into a single session where agency requirements are similar. However, you must assure that you comply with each rule individually.
If I am trained by Lion, will I be "certified"?
The US DOT does not require "certification" or "licensing" of hazardous materials shippers in the way that a person may be licensed to practice plumbing, be registered as a professional engineer, be certified as an accountant, or be licensed to drive a vehicle.

The DOT requires that any hazmat employee training must include:
  • Testing of each individual (written, oral, by demonstration, or otherwise) to assure that the person was trained; and
  • Certification by the employer, in a "record of training" kept in the employer's files, that the employee was trained and tested.
To assist in complying with DOT's training requirements, all Lion workshops and web-based training courses include exercises throughout the program and quizzes at completion. Upon passing the test, each student receives a Certificate of Achievement from Lion Technology, documenting that the person was trained and tested. The Lion certificate may be used by the employer as part of the required "record of training."
If I am trained by Lion, can I train others?
DOT's training standard does not impose any specific requirements for qualification of trainers. DOT does not "approve," "certify," or otherwise accredit hazardous materials transportation trainers or training programs.

All of Lion's training products and services are designed to train you in regulatory requirements for management of hazardous materials. While our courses and workshops are not designed to teach you how to be a trainer, you will learn what you need to teach your personnel.  DOT Hazmat Shipper Training for Managers. 
What training does Lion provide?
Lion Technology offers a suite of hazmat transportation training options designed to meet all of your training needs.

Lion presents regularly scheduled, open-enrollment, public training workshops across the United States all year long. These workshops cover EPA and DOT regulations. In the area of DOT hazardous materials transportation, our Hazmat Ground Shipper Certification (DOT) workshop is presented approximately 60 times per year.

Online training courses are available on Lion's website 24 hours a day. For a listing of currently available online courses, visit our course catalog.

Finally, Lion provides webinars intermittently throughout the year on several key topics. To see a listing of our webinars, visit our course catalog.
Should I take an online course or attend a public workshop?
The choice between attending a public workshop and taking an online training course is a personal decision. You should consider the following:
  • What is your style of learning?
    • If you like classroom-style, live, instructor-led training where you can talk face to face with your neighbor or with the instructor during breaks and work on exercises with others, Lion's public workshops offer all of these.
    • If you prefer to work at your own pace, have the option to review the information you've learned as many times as you need to, work on exercises when you feel you're ready, and still have e-mail dialog with an instructor, web-based training courses provide this approach to learning.
  • How much time do you have?
    • If you'd like to get out of the office for two days, get your training all at once and head back to work with a bunch of fresh ideas and tools to apply to your job, the public workshops offer all of these.
    • If you find that you can't afford to take two full days away from the office, or just prefer to get your training in increments, applying the information as you learn, you might prefer Lion's online training courses, which are divided into brief, focused lessons.
  • When do you need training?
    • Lion presents over 200 workshops per year nationwide, so chances are one will come to a major metropolitan area convenient for you during the year. Some workshops are presented in key cities more than once per year! If you've decided to attend a public workshop, you can plan to attend the one most convenient for you.
    • If you want access to training immediately and whenever you need it, without traveling, Lion's online training courses are available 24 hours a day via the Internet.
Do I have to have hazardous materials training just to sign a manifest?
Yes. If a person ships an EPA-regulated hazardous waste and that waste is required the use of a manifest, then that material is subject to the DOT Hazardous Materials Regulations (HMR). In fact, there is a specifically worded certification statement on the manifest that certifies that the shipment complies with all applicable DOT requirements. 

As such, the person signing the manifest is performing a regulated function and would be required to receive training as a hazmat employee.  DOT Hazmat Training for Signing a Manifest.

Read more about training required to sign the Hazardous Waste Manifest. 
Is my certificate from Lion the only training record I need?
No. The US DOT hazmat employee training standard requires the “hazmat employer” to prepare and retain a record of training for each hazmat employee. [49 CFR 172.704(d)] 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; and
  • A certification by the hazmat employer that the hazmat employee has been trained and tested.
While much of the above information can be found on your Lion Certificate of Achievement, there are components that can only be prepared back at the workplace. For instance, it is the hazmat employer who must ultimately certify training and testing have been completed. 
What is a “hazardous material?”

A hazardous material is defined as “a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous . . . .” [49 CFR 171.8]

Can I be penalized if I do not receive required hazmat training?
If you are a hazmat employee, then you are required by law to get trained on DOT’s hazmat regulations and will be fined if a DOT inspector finds that you lack training. Training violations have a minimum fine of $481 per person, per day. [49 CFR 107.329(a)] Find DOT Hazmat Training Options Now
Do I need separate training if I ship by air or vessel?
Typically, those who ship hazmat by air will need additional training on the International Air Transport Association (IATA) Dangerous Goods Regulations, and those who ship by vessel will need more training on the International Maritime Dangerous Goods (IMDG) Code. If you ship hazardous materials by air or vessel, visit our page on who needs IATA or IMDG dangerous goods training.

How long do I have to keep my DOT training records?
Under DOT rules, a hazmat employer must keep all current training records for each hazmat employee for 90 days after their employment ends. In addition, training records dating back at least three years must be available upon request. [49 CFR 172.704(d)]
Will training with Lion help me maintain my professional certifications?
Lion offers Continuing Education Units (CEUs), calculated based on training hours, which can be submitted for approval to help you maintain certifications and licenses with AHMP, ABIH, IHMM, SLRP, NEHA, 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.