Regulatory Requirements | FAQs & Resources

Dangerous Goods Transportation Training Regulatory Requirements

Currie Associates provides in-house hazardous materials / dangerous goods training courses and auditing services for many small and large multinational companies as well as some of the world’s largest transportation companies, covering topics such as 49 CFR, ADR, IATA / ICAO, IMDG COde, Transportation of Batteries, Multimodal courses, and more.

Click below to review the following training requirements:

 

FAQs

Here you’ll find answers to the most commonly asked questions regarding dangerous goods training. Learn more about who needs training, why they need it and how often training is needed below.

 

Q. Who Needs to be Trained?

The United States Department of Transportation (US DOT), International Maritime Organization (IMO), the European Union, the International Civil Aviation Organization (ICAO), and other regulatory bodies require that all dangerous goods employees receive training. Anyone involved in the preparation or transport of dangerous goods in your company is required to be trained.

  • US DOT Pipeline and Hazardous Materials Safety Administration (PHMSA): requires every hazardous materials (hazmat) employer to train, test, and certify all hazmat employees as defined in 49 CFR Section 171.8.
  • International Maritime Dangerous Goods (IMDG) Code: requires shoreside personnel be trained before assuming responsibilities and permits certain functions to be performed under direct supervision.
  • International Civil Aviation Organization (ICAO) Technical Instructions (TI) and the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR): require personnel are competent to perform any function they designated to perform prior to performing the functions.

The specific responsibilities of hazmat employers and the training requirements in the United States are found in Title 49 of the Code of Federal Regulations (CFR), Part 172, Subpart H. For ocean transportation they are found in the IMDG Code, Chapter 1.3, and in the IATA DGR Section 1.5 for air transport.

Hazmat Employee Examples:

  • Hazardous Materials / Dangerous Goods Manager
  • Regulatory Affairs Coordinators
  • Production Supervisors
  • Cargo Handlers
  • Shipping Supervisors
  • Shipping Clerks
  • Warehouse Supervisors
  • Purchasing Agents
  • Drivers
  • Packaging personnel
  • Stowage planners
  • Any person who designs, tests, marks, manufactures, reconditions, repairs packagings or is responsible for safety in transporting hazardous materials meets the definition of “hazmat employee” in 49 CFR section 171.8.

Q. What Are Pre-Transportation Functions?

Hazmat Employee Pre-Transportation Functions may include:

  • Classifying products or materials
  • Packing
  • Marking, labeling, or placarding
  • Loading/unloading cargo
  • Preparing, validating, or signing transport documents
  • Offering materials for transport
  • Accepting or receiving materials
  • Handling in transport
  • Preparing or loading
  • Transporting or carrying

Q: How often do hazmat/dangerous goods employees need to be trained?

  • Initial Training is required for a newly on-boarded hazmat employee and an existing employee who changes job functions to become a hazmat employee. Both are allowed 90 days to complete their required training. During their initial 90 days, they must work under the direct supervision of a trained employee until their training requirement has been fulfilled. Note that ICAO/IATA does not provide for a 90-day time frame and requires initial training prior to an employee performing a hazmat function.
  • Recurrent Training is required every three (3) years in compliance with the HMR (49 CFR) and as needed in supplemental courses, refreshers, or when the regulations change. The IMDG Code does not specify a recurrency interval, indicating only that initial training shall be periodically supplemented relying on the Competent Authority to enforce the frequency of the refresher training. ICAO/IATA require recurrent training every 24 months. Many companies opt to provide hazmat training more frequently, such as every 2 years for all modes, to maintain compliance.

Q: What Training Topics Need to be Covered?

  • General & Security Awareness Training must provide awareness of hazmat security risks, enable the employee to recognize and identify hazardous materials, and familiarization with the HMR requirements.
  • Safety Training must provide information on the requirement to provide an emergency response telephone number, emergency response information, and measures to protect the employee from hazards in the workplace.
  • Function-Specific Training is specific to the job responsibilities or functions performed by a hazmat employee. The employer must ensure employee job functions are identified and training addresses those responsibilities.

Examples of Function Specific Training:

  • How to prepare shipping papers.
  • How to mark and label packages that are filled with hazardous materials.
  • How to specifically work in compliance with Special Permits and Exemptions.

 

Q: What is the difference between “general awareness” and “function specific” training?

General Awareness or familiarization training must provide familiarity with the requirements of the HMR and enable hazmat employees to recognize and identify hazardous materials using the hazard communication standards.

Function Specific training is specific to the functions employee performs (e.g. marking, labeling, documentation, loading/unloading) and meets requirements of Subchapter C, or special permits issued under subchapter A.

Q: Can the Hazmat Employer Hire a Third-Party Company to Provide Hazmat Training?

Yes. Employers are responsible for their hazmat training program, to include identifying employee functions and the required training content. The regulations (49 CFR Section 172.702(c)) state that a third-party source may provide the training and test hazmat employees on behalf of the employer. Currie Associates provides customized hazmat training courses for 49 CFR, ICAO/IATA, IMDG Code, ADR, Transport Canada TDGR, Lithium Batteries, Excepted/Limited Quantities, Materials of Trade, etc. To learn more about Currie Associates training, visit the Currie Associates website – https://www.currieassociates.com/hazmat-training/.

 

Q: How Do I Properly Keep Training Records?

The United States Department of Transportation (USDOT), Pipeline and Hazardous Materials Safety Administration (PHMSA), International Maritime Dangerous Goods (IMDG) Code, International Civil Aviation Organization (ICAO), the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) and competent authorities require employers to maintain training records. The elements for the training records are found in 49 CFR Section 172.704(d), IMDG Code 1.3.1.3, ICAO 4.2.5 and IATA 1.5.1.4. Additional requirements may be specified by the competent authority.

The HMR, under 49 CFR Section 172.704(d), provides the specific recordkeeping requirements for hazardous materials training. Hazmat employers must keep training records for a minimum of 36 months for current employees while also maintaining training records for 90 days following the employee’s separation from the company. Training records may be electronic or physical copies provided they can be made available to an authorized USDOT official, inspector, or other HMR enforcement officer upon request. The regulations do not dictate the format of the training record, they identify the required elements that must be present.

 

Q: What Must Training Records Include?

  • Hazmat employee’s name and company name
  • The date (and month for air) of the most recent training completion
  • A description, copy, or the location of the training materials used
  • The name and address of the person who provided the training; and
  • Certification that the hazmat employee has been trained and tested

Q: Should Hazmat Employees Be Tested After Training?

Yes, to satisfy the requirements of 49 CFR 172.702(d), employers must test hazmat employees by appropriate means. IATA requires an ongoing assessment by the employer to verify competence in the functions the employee must perform.

 

Q: Should Hazmat Employee Test Scores Be Kept On File?

No, the regulations do not mention test scores and do not dictate the type of assessment that must be performed (e.g., written, oral, performance or hands on); however, employers must still produce evidence of training and testing indicating a pass/fail performance. To satisfy 49 CFR 172.704(d)(5), a certificate indicating the hazmat employee has been trained and tested should be kept on file.

 

Q: What References Should Hazmat Employees Have Access To?

It is essential for hazmat employees to have access to the latest editions of the regulations to successfully complete their training and ultimately prepare compliant shipments. Depending on your facility and operation, each facility should have at least one current paper copy or electronic access to the regulations for preparing consignments for ground, air, and ocean transport in accordance with the modes of transport you offer hazardous materials shipments.

Should a regulatory enforcement inspector discover that your company does not have access to the current regulations, they may deem your operation out of compliance. It would be difficult to prove that you properly abide by the federal requirements if you cannot produce the most current edition of the regulations.

It is acceptable to maintain older versions of the regulations for reference purposes and it is recommended that you mark them as “for reference use only.” Communicating the reference use of the books will help prevent confusion amongst operational staff from mistakenly using older or out of date versions of the regulations.

To learn more about the current regulatory code books, visit the Currie Associates Online Book Shop: currieshop.com

Links to other helpful industry FAQs:

US DOT PHMSA
Federal Motor Carrier Safety Administration (FMCSA)
International Air Transport Association (IATA)
International Civil Aviation Organization (ICAO)
International Maritime Organization (IMO)
US DOT Federal Railroad Administration (FRA)
US DOL OSHA Hazard Communication (HAZCOM)

 

Helpful DG/Hazmat Resources & Links

US Federal Registers

US Government Printing Office GPO Access Website:

US Government Agencies

International Agencies