U.S. DOT Training Requirements
Congress gives The U.S. Department of Transportation (DOT) the authority to issue regulations for the safe transportation of hazardous materials in intrastate, interstate and foreign commerce. This authority was granted in the Hazardous Materials Transportation Act (HMTA), first adopted in 1974 and amended in November, 1990, as the Hazardous Materials Transportation Uniform Safety Act of 1990 (HMTUSA).
In response to this mandate, the U.S. DOT has built up a body of rules called the Hazardous Materials Regulations (HMR). These regulations are maintained by the Research and Special Projects Administration (RSPA).
HMRs are contained in Title 49 of the Code of Federal Regulations (CFR), Parts 171–180. Each numbered part deals with a single subject and is then divided into subsections, as follows:
Part 171: Includes definitions, reporting requirements, reference materials and procedural requirements.
Part 172: Includes the Hazardous Materials Table and hazard communication requirements.
Part 173: Contains the hazard class definitions for classifying materials, lists DOT packagings authorized for specific materials and references the appropriate sections of Part 178 when DOT specification packagings are required.
Part 174: Transportation by rail car.
Part 175: Transportation by aircraft.
Part 176: Transportation by vessel.
Part 177:Transportation by motor vehicles.
Part 178: Contains specifications for a wide variety of approved packagings.
Part 179: Specifications for tank cars.
Part 180: Requirements for continuing qualification and maintenance of packagings.
In a notice published at 57 Fed. Reg. 20953 (15 May 1992) the U.S. DOT established new training requirements for hazmat employees by creating a new Subpart H Training (49 CFR 172.700 - .704). The initial proposal was assigned a Docket Number of HM-126F Training for Safe Transportation of Hazardous Materials program.
Training, as defined in Subpart H, means a systematic program that ensures a hazmat employee:
- Is familiar with the general provisions of the HMR
- Is able to recognize and identify hazardous materials
- Has knowledge of specific requirements of the HMRs applicable to the functions performed by the employee
- Has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures
A hazmat employee is a person who is employed by a hazmat employer and who, in the course of employment, directly affects hazardous materials transportation safety.
A hazmat employer is a person (including a business or organization) that uses one or more of its employees in connection with:
- Transporting hazardous materials in commerce
- Causing hazardous materials to be transported or shipped in commerce
- Representing, reconditioning, marking, testing, certifying, repairing, selling, modifying or offering containers, drums or packagings to qualify them for use in the transportation of hazardous materials
General Training Requirements
Each hazmat employee must receive initial and recurrent training that includes:
- General awareness/familiarization training
- Function-specific training
- Safety training
- Security awareness training
- In-depth security training
General awareness/familiarization training is designed to provide familiarity with DOT regulations for shippers, transporters and manufacturers and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards of the DOT regulations.
Function-specific training relates to the requirements of DOT regulations for shippers, transporters and manufacturers that are specifically applicable to the functions the employee performs.
Safety training must cover:
- Emergency response information required by 49 CFR Part 172, Subpart G Emergency Response Information
- Measures to protect the individual employee from the hazards associated with hazardous materials to which he or she may be exposed in the work place. Specific measures the hazmat employer has implemented to protect employees from exposure must be included
- Methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials
Each employer must test each of it's hazmat employees by appropriate means.
Initial and Recurrent Training
A new hazmat employee or a hazmat employee who changes job functions must complete training requirements for the new job function(s) within 90 days. However, the employee may perform new hazardous materials job functions prior to the completion of training, provided the employee performs those functions under the supervision of a properly trained and knowledgeable hazmat employee.
Hazmat employees must receive the required training at least once every three years.
Each hazmat employer must create and retain a record of current training for each hazmat employee. The record must include information for at least the last three years. This record must be retained for as long as that employee is employed as a hazmat employee and for 90 days thereafter.
The training records must include the following information:
- Hazmat employees name
- Most recent training completion date
- Description, copy or location of training materials used
- Name and address of the person providing the training
- Certification that the hazmat employee has been trained and tested as required.
Specialized Training for Drivers
49CFR 177.816 regulations require that no carrier may transport, or cause to be transported, a hazardous material unless each hazmat employee who will operate a motor vehicle has been trained in the applicable requirements of 49 CFR Parts 383, 387, 390, 399 and the procedures necessary for the safe operation of that motor vehicle.
Commonly asked Questions
|Q.||Can the hazard communication training required by the Occupational Safety and Health Administration be used to satisfy the U.S. DOT safety training requirements?|
|A.||Yes, if the training addresses the DOT safety training elements, it may be used to satisfy the requirements.|
|Q.||Who must provide the required training?|
|A.||The hazmat employer or certain other public or private sources. Two organizations that offer DOT training are DGI (800-338-2291) and Lion Technology Inc. (973-383-0800).|
|Q.||What are some examples of employees requiring hazmat training?|
|A.||Employees who: |
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The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.
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