A hazmat employee is a person who is employed by a hazardous materials employer and “directly affects hazardous materials transportation safety.”
Now, the regs also provide examples of hazmat employees to be sure you follow the rules. Examples include, those who load, unload, or otherwise handle hazmats; operators of vehicles transporting hazmats; employees who test, repair, modify, mark, or otherwise represent packagings as qualified for transporting hazmats; employees who prepare hazmats for transportation; and employees who are responsible for safety in the transportation of hazmats.
Despite the examples, the provision that a hazmat employee is one who “directly affects hazmat transportation safety” is notable for being nonspecific. The regulations clearly intend that any individual who has any impact on the safety of hazmats in transportation is considered a hazmat employee who requires training and certification. This could also be, for example, an office assistant who types the required hazardous materials description on a shipping paper at the direction of another is a hazmat employee and must be trained, tested, and certified.