Posted on January 19, 2018
I Have a Hazmat Certificate – Does This Mean I’m Certified?
A certificate of completion, or a certificate of attendance, is not the same thing, nor is it equal to being nationally or state certified. Being certified means your proficiency has been assessed by DGI Training. It is official recognition that you possess certain qualifications and meet certain standards. So at the end of the day upon successful completion of our exams we issue a certificate which says you attended and demonstrated the proficiency necessary to obtain the certificate (a piece of paper).
As you know 49CFR is our American law. In 49CFR, Section 172.704(d) – Record keeping, it lays out five requirements;
(1) The hazmat employee's name;
(2) The most recent training completion date of the hazmat employee's training;
(3) A description, copy, or the location of the training materials used to meet the requirements in paragraph (a) of this section;
(4) The name and address of the person providing the training; and
(5) Certification that the hazmat employee has been trained and tested, as required by this subpart.
It’s mambo number five that hits home. How does the employer “certify” that the employee has been properly trained and tested? DGI provides the training and the proficiency testing, but it is up to the employer to “certify” that the employee has received the appropriate training & testing. After much research and conversations with the DOT there is no definition of “certifying.” I did find a couple of letters of interpretation (PHMSA #15-0071 & #14-0216) which say, that the employer must utilize the first four requirements above to “certify” the employee has been trained and tested. The employer’s signature on a DGI certificate verifies that these requirements have been met and certifies your hazmat proficiency.
These are our requirements here in America. With DGI’s online training we have to be sure the training, testing, recordkeeping requirements, and certification meet the requirements which may be different in your part of the world. Our Canadian friends to the north, for example, must have information on their certificates which isn’t required on our certificates. The Canadian Regulations called, Transport Dangerous Goods or TDG, Part 6.3 explains that the certificates must include;
(a) the name and address of the place of business of the employer; The place of business could be a local office, a regional office or a head office.
(b) the employee's name;
(c) the date the training certificate expires, preceded by the words “Expires on” or “Date d'expiration”; and
(d) the aspects of handling, offering for transport or transporting dangerous goods for which the employee is trained, including the specific topics set out in section 6.2.
So for our Canadian friends, please make sure the name and address of your company is printed on your certificate regardless of who provides it. Wherever you are, please make sure your training needs and requirements meet the standards of your government.