Who Needs Dangerous Goods Training?
Internationally, hazardous materials are referred to as "dangerous goods" or DG. If you ship hazmat/DG by air or vessel (even within the United States) you likely need to comply with international standards like the IATA Dangerous Goods Regulations (DGR) and the IMDG Code.
US DOT requires hazmat employees training to cover all applicable modal requirements. This FAQ highlights hazmat/dangerous goods training requirements for air and vessel shippers.
DG Training FAQ: IATA DGR and IMDG Code
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.
Hazmat air shippers must comply with stricter employee training rules. The IATA DGR requires recurrent training at least every 24 months [IATA 22.214.171.124] 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 126.96.36.199]
- Shippers (and persons undertaking the responsibilities of shippers’ , including operator staff acting as shippers, operator’s staff preparing dangerous goods as Company Materials (COMAT))
- Staff of freight forwarders involved in processing dangerous goods
- Staff of freight forwarders involved in processing cargo, mail, or stores (other than dangerous goods)
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.
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- The hazmat employee’s name;
- The most recent training completion date of the hazmat employee’s training;
- A description, copy, or the location of the training materials used;
- The name and address of the person providing the training; and
- Certification by the hazmat employer that the hazmat employee has been trained and tested, as required.
- “A copy of the certification received when the individual was trained, which shows that a test has been completed satisfactorily.”
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.
Purchase the current edition of the IMDG Code here.
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.
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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.
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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.
Learn more about dangerous goods training options:
Hazardous Materials Air Shipper Certification
Hazardous Materials Vessel Shipper Certification
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.
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.
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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.
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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.