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.
|Mode||49 CFR |
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:
Employees Must Be Trained in the Following Areas:
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.
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.
Minimum Requirements for Training Curricula (1.5.2)
|Aspects of transport of dangerous goods by air with which they should be familiar, |
as a minimum
|Category of Personnel See key below|
|General requirements for shippers||X||.||X||.||.||X||.||.|
|List of dangerous goods||X||X||X||.||.||X||X||.|
|General packing requirements||X||X||X||.||.||X||.||.|
|Labeling and marking||X||X||X||X||X||X||X||X|
|Shipper's Declaration and other relevant documentation||X||.||X||.||.||X||.||.|
|Storage and loading procedures||.||.||X||X||.||.||X||.|
|Provisions for passengers and crew||.||.||X||X||.||X||X|
|Key:||1 -||Shippers and shipper's agents|
|3 -||Cargo acceptance staff of operators and agencies acting on behalf of operators|
|4 -||Staff of operators and agencies acting on behalf of operators engaged in the ground handling, storage and loading of cargo and baggage|
|5 -||Passenger handling staff and security staff who deal with the screening of passengers and their baggage|
|6 -||Staff of agencies other than operators involved in processing cargo|
|7 -||Flight crew members|
|8 -||Crew members (other than flight crew)|
|Note:||Depending on the responsibilities of the person, the aspects of training to be covered may vary from those shown in Table 1.5.A -- e.g. if may be more appropriate for a packer to cover the aspects with which a shipper should be familiar; if an operator carries only cargo, those aspects relating to passengers may be omitted from the training programme for his staff and flight crew.|
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
|Mode||12 Months||24 Months||3 Years|
|Airline Employees (within the USA only)||X||.||.|
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.