HazMat Training Requirements

This is a commonly misunderstood area, but it is really quite simple. If a motor carrier transports hazardous materials (regardless of quantity, frequency, or type), all employees who in any way are responsible for that material (e.g., shipping clerks, dock workers, or drivers) MUST be trained in accordance with §172.704 Training Requirements. There are no exceptions. Hazmat employee training must include the following:

General Awareness/Familiarization Training. General Awareness/Familiarization training must be completed initially upon hire and at least once every three (3) years thereafter. A current record of the training must be kept the entire time the employee works for the company. The record must include:

1. The HazMat employee’s name.
2. The most recent training completion date of the training.
3. A description, copy, or the location of the training materials used.
4. The name and address of the person providing the training.
5. Certification that the HazMat employee has been trained and tested as required by this HMR subpart.

In addition to the General Awareness/Familiarization training, function-specific training is also required. The difference is that, essentially, general awareness training is an overview of the HMR. Function-specific training focuses more on the functions that those particular employees perform. For example, shipping clerks would receive function-specific training on Hazardous Material bills of lading, the Hazardous Materials table, etc.; dock workers’ training would include labeling and packaging; and drivers’ training is discussed below.

Function-Specific Training for Drivers. The Function-Specific training rules for drivers are found in FMCSR §177.816.This training must include:

1. Pre-trip safety inspections.
2. Use of vehicle controls and equipment, including operation of emergency equipment.
3. Operation of vehicle, including turning, braking, backing, parking, handling, and vehicle characteristics including those that affect stability, such as effects of braking and curves, effects of speed on vehicle control, dangers associated with maneuvering through curves, dangers associated with weather or road conditions that a driver may experience (e.g., blizzards, mountainous terrain, high winds, and high center of gravity).
4. Procedures for maneuvering tunnels, bridges, and railroad crossings.
5. Requirements pertaining to attendance of vehicles, parking, smoking, routing, and incident reporting.
6. Loading and unloading of materials, including compatibility and segregation of cargo in a mixed load, package handling methods and load securement.

There are additional rules found in §177.816(b) for drivers who operate cargo tanks and portable tanks. There is an exception: If the driver has a CDL license with a hazardous materials or tank vehicle endorsement, Function-Specific training is not required. However, as noted, there are no exceptions to the General Awareness training requirements, and drivers must still receive that training once every three years.

Security Awareness Training. No later than the date of the first scheduled recurrent training after March 25, 2003, and in no case later than March 24, 2006, each HazMat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats. After March 25, 2003, new HazMat employees must receive the security awareness training required by this paragraph within 90 days after employment.

In-Depth Security Training. Each hazmat employee of a person required to have a security plan in accordance with subpart I of this part who handles hazardous materials covered by the plan, performs a regulated function related to the hazardous materials covered by the plan, or is responsible for implementing the plan must be trained concerning the security plan and its implementation. Security training must include company security objectives, organizational security structure, specific security procedures, specific security duties and responsibilities for each employee, and specific actions to be taken by each employee in the event of a security breach.

OSHA, EPA & Other Training. Training conducted by employers to comply with the hazard communication programs required by the Occupational Safety and Health Administration of the Department of Labor (29 CFR §1910.120 or §1910.1200) or the Environmental Protection Agency (40 CFR §311.1), or training conducted by employers to comply with security training programs required by other Federal or international agencies, may be used to satisfy the training requirements in paragraph (a) of this section to the extent that such training addresses the training components specified in paragraph (a) of this section.

Note: Don’t confuse the DOT’s hazardous materials training requirements with OSHA’s hazard communication (often referred to as “haz-comm” or “right-to-know”) training requirements. They are very different types of training – in other words, one will not satisfy the requirement for the other.