All persons that work in the Dangerous Goods/Hazardous Materials transportation field must be trained. Training requirements are based on the mode of transport (air, ocean, highway, rail) used and the job function performed.

No matter which mode of transport used, the employer/employee must adhere to the training requirements under 49 CFR, Subpart H. For all modes, all job functions, the following apply:

• It is the employer's responsibility to ensure their employees receive training.
• The employee may not perform their duties unless they have received training.
• The employer may provide training or use an outside source.
• The training must include a test.

Employees Must Be Trained in the Following Areas:

• General Awareness training: provides familiarity with the requirements and allows employees to recognize hazardous materials (dangerous goods) in their workplace.
• Function-specific training: detailed job-specific training. Example; if you mark and label packages, your training must include detailed information on those subjects.
• Safety training: includes emergency response and measures to be taken in case of an emergency at your workplace. This training should also include proper handling procedures to avoid mishaps.

Other Requirements:

• The employee must be trained within 90 days of hire or a change in job function(s).
• Until trained, the employee may perform their job only under the direct supervision of a properly trained and knowledgeable hazmat employee.
• Relevant training received from a previous employer or other source will satisfy the requirements as long as you have training records from the previous employer.
• Employee records must be kept and include the following:
  • Employee's name.
  • Date of most recent completed training.
  • A description, copy, or the location of the training materials used.
  • Name and address of who provided the training.
  • Certification that the employee has been trained and tested.

Retention of Records:
Records of current training, as well as the preceding three years, must be maintained for each employee. If the employee leaves, the records must be kept for an additional 90 days. The training records must be made available upon request of the appropriate authority.

In addition to the above requirements under 49 CFR, if you transport by air or ocean, there are additional regulations you must comply with. For air transport on an IATA carrier, you must be certified to use the ICAO/IATA Dangerous Goods Regulations. For ocean shipments you must be trained according to the IMDG regulations. The training requirements are almost identical with the exception of recurrent training frequency.

Training Curriculum

Table 1.5.A in the IATA Dangerous Goods Regulations is based on ICAO Table 6-1, Content of Training Courses. It may be used as a guideline applicable to most modes.

TABLE 1.5.A
Minimum Requirements for Training Curricula (1.5.2)

Training Frequency

Once initial training has been completed, you must receive recurrent training to remain up-to-date on any changes to the regulations. The frequency depends on the mode or job. However, in addition to the chart indicating training frequencies, current US Department of Transportation regulations also state that "...training is required every time changes in the regulations occur." This pertains only to the hazardous materials you transport or your job function. *The IMDG Code does not reference a time frame therefore the 3-year recurrent period stated in 49 CFR, Subpart H, applies.

Recurrent Training Schedule

References

IATA - International Air Transport Association Regulations,

ICAO - International Civil Aviation Organization

49 CFR - The 49th Code of Federal Regulations -

IMDG - International Maritime Dangerous Goods Code.

14 CFR - Code of Federal Regulations, Subpart A, Part 121.433a and 135.333.