DOT Training Requirements – HazMat Employees

DOT Training Requirements – HazMat Employees

Listed below are DOT training requirements for “Hazmat Employees”.  (Hazmat employees are defined as follows:)

A person employed on a full-time, part-time or temporary basis who in the course of such employment directly affects hazardous materials transportation.
This term includes any of the above individuals who during the course of their employment perform any of the following functions:
Loads, unloads or handles hazardous materials;
Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package, container or packaging component that is represented, marked, certified or sold as qualified for use in transporting hazardous material in commerce.
Prepares hazardous materials for transportation;
Is responsible for safety of transporting hazardous materials;
Operates a vehicle used to transport hazardous materials.

Hazmat training for Hazmat Employees must include the following:

General Awareness/familiarization training:  Each Hazmat Employee shall be provided general awareness/familiarization training designed to provide familiarity with the requirements of the Hazmat Regulations, and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards of the regulations.
Function-specific training:
Each Hazmat Employee must be provided function-specific training concerning the requirements of the Hazmat Regulations that are specifically applicable to the functions that the employee performs; e.g., driving, preparing shipping papers, loading hazardous materials, etc.
As an alternative, training related to the requirements of the International Maritime Dangerous Goods (IMDG) Code may be provided to the extent that such training meets the requirements of the Hazmat Regulations.
Safety training:   Each Hazmat Employee shall receive safety training concerning:
Emergency response information required by the Hazmat Regulations;
Measures to protect the employee from the hazards associated with hazardous materials to which they may be exposed in the work place, including specific measures the Hazmat Employer has implemented to protect employees from exposure; and
Methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials.
Security awareness training:  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.
In-depth security training:  Each Hazmat Employee of a company required to have a security plan in accordance with the Hazmat Regulations must be trained concerning the security plan and its implementation.  Security training must company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach and the organizational security structure.

Initial and recurrent training:

Initial training – A new Hazmat Employee, or a Hazmat Employee who changes job functions may perform those functions prior to the completion of training provided that:
The employee performs those functions under the direct supervision of a properly trained and knowledgeable Hazmat Employee; and
The training is completed within 90 days after employment or a change in job function.
Recurrent training – A Hazmat Employee shall receive the training required by the Hazmat Regulations at least once every three (3) years.

Source: R. Fricke August 2009