DOT Hazmat Employee Training Awareness

What counts as hazardous material and transportation

A hazardous material (hazmat) is a substance or material that the Secretary of Transportation has found can pose an unreasonable risk to health, safety and property when transported in commerce, and has designated as hazardous. It includes:

• Hazardous substances and hazardous wastes
• Marine pollutants and elevated temperature materials
• Materials listed in the Hazardous Materials Table (49 CFR 172.101)
• Materials that meet the criteria for the hazard classes and divisions in part 173

The HMR are parts 171 through 180 of Title 49.

Transportation is more than driving

Transportation means moving property, plus the loading, unloading and storage that go along with that movement. And commerce includes trade or transportation within a single state, not only across state lines.

Reference: 49 CFR 171.8 "Hazardous material" · 49 CFR 171.8 "HMR" · 49 CFR 171.8 "Transportation or transport" · 49 CFR 171.8 "Commerce"

Hazmat employees and hazmat employers

You are a hazmat employee if you work full time, part time or on a temporary basis for a hazmat employer (or are self-employed) and your work directly affects hazardous materials transportation safety. That includes anyone who:

People who design, make, inspect, mark, repair or test packaging represented, marked, certified or sold as qualified for hazmat are covered too.

Hazmat employer

A hazmat employer employs or uses at least one hazmat employee and transports hazmat in commerce, causes it to be transported, or makes or tests qualified hazmat packaging. Federal, state, local and tribal government agencies can be hazmat employers too.

Reference: 49 CFR 171.8 "Hazmat employee" · 49 CFR 171.8 "Hazmat employer"

Pre-transportation functions

A pre-transportation function is a job required by the HMR to make sure hazmat travels safely. If you do any of these, the rules apply to your work:

Reference: 49 CFR 171.8 "Pre-transportation function"

Shipping words you will hear

• Shipping paper: a shipping order, bill of lading, manifest or similar document prepared under the HMR's shipping paper rules.
• Marking: the name, identification number, instructions, cautions, weight, specification or UN marks required on the outer packaging.
• Packaging: the container and anything else it needs to hold the material safely. A package is the packaging plus what is inside it.

Bulk or non-bulk?

Solids and gases have their own size limits in the definitions.

Reference: 49 CFR 171.8 "Shipping paper" · 49 CFR 171.8 "Marking" · 49 CFR 171.8 "Packaging" · 49 CFR 171.8 "Package or Outside Package" · 49 CFR 171.8 "Non-bulk packaging" · 49 CFR 171.8 "Bulk packaging"

Key terms in the HMR

These words show up on shipping papers, in the Hazardous Materials Table and in your training. Learn what each one means.

Reference: 49 CFR 171.8 "Hazard class" · 49 CFR 171.8 "Division" · 49 CFR 171.8 "Primary hazard" · 49 CFR 171.8 "Subsidiary hazard" · 49 CFR 171.8 "Packing group" · 49 CFR 171.8 "Proper shipping name" · 49 CFR 171.8 "Limited quantity" · 49 CFR 171.8 "Undeclared hazardous material"

What hazmat training must include

Reference: 49 CFR 172.704(a)(1) · 49 CFR 172.704(a)(2) · 49 CFR 172.704(a)(3) · 49 CFR 172.704(a)(4) · 49 CFR 172.704(a)(5)

Other training that may count, and some limits

Other training can count

Training your employer gives to meet OSHA hazard communication rules (29 CFR 1910.120 or 1910.1200), EPA rules (40 CFR 311.1), or other federal or international security training may be used to meet DOT's training requirements, but only to the extent it covers the DOT training components.

For function-specific training, training on the ICAO Technical Instructions and the IMDG Code may be used instead, to the extent it covers functions allowed under part 171, subpart C.

A few limits

• An employee who only makes, repairs, modifies, reconditions or tests qualified packaging, and does nothing else regulated, does not need the safety or security awareness training.
• A railroad maintenance-of-way employee or railroad signalman who does not perform any function regulated by the HMR does not need function-specific, security awareness or in-depth security training.

Reference: 49 CFR 172.704(b) · 49 CFR 172.704(a)(2)(ii) · 49 CFR 172.704(e)(1) · 49 CFR 172.704(e)(2)

When training must happen

New job or new duties

A new hazmat employee, or one who changes job functions, may do those functions before training is finished only if both of these are true:

• You work under the direct supervision of a properly trained and knowledgeable hazmat employee, and
• Your training is completed within 90 days after employment or the change in job function.

Refresher

Hazmat training must be repeated at least once every three years. For in-depth security training, if the security plan is revised during that cycle, training on the revised plan is due within 90 days of putting it in place.

Training from somewhere else

Relevant training from a previous employer or another source can count, if a current record of that training is obtained from the previous employer.

Reference: 49 CFR 172.704(c)(1) · 49 CFR 172.704(c)(2) · 49 CFR 172.704(c)(3) · 49 CFR 172.704(c)(4)

The training record

Your employer must create and keep a record of your current training, covering the preceding three years. It must be kept for as long as you work there as a hazmat employee and for 90 days after. On request, it must be made available at a reasonable time and place to an authorized DOT official or other entity explicitly given authority to enforce the HMR.

The record must include

• Your name
• Your most recent training completion date
• A description, copy or the location of the training materials used
• The name and address of the person who provided the training
• Certification that you have been trained and tested

Reference: 49 CFR 172.704(d) · 49 CFR 172.704(d)(1) · 49 CFR 172.704(d)(2) · 49 CFR 172.704(d)(3) · 49 CFR 172.704(d)(4) · 49 CFR 172.704(d)(5)