8 Things You Can’t Forget When Training HazMat Employees

According to the letter, responsible hazmat employers, either individually or through industry associations, are best qualified to determine the training needs of their employees. “No attempt has been made to specify the level and duration of training or testing,” states the letter.

Here are 8 things from a DOT guidance document that you should keep in mind when training your employees on hazmat transportation:

1. DOT requirements for hazardous materials transportation training depend on the job duties. Of the types required, two involve security training. First, each hazmat employee must have “awareness” training that addresses security risks associated with hazmat transportation and methods designed to enhance transportation security. Second, in-depth security training is required for employees if the employer is required to have a security plan.
2. DOT has developed specific requirements for air, vessel, and highway hazmat transportation to regulate those modes of transportation.
3. New employees don’t have to be trained right away—if they work under the supervision of another trained employee. A new employee or an employee who changes position may perform hazmat job functions if he or she is under the direct supervision of a properly trained and knowledgeable hazmat employee, and the hazmat training for the new/transferred employee is completed within 90 days of employment or change in job function.
4. Relevant training received from a previous employer or another previous source may be used to satisfy the requirements provided a current record of training is available.
5. The training record also has requirements. A training record must include the hazmat employee’s name, completion date of the most recent training, training materials, name and address of hazmat trainer, and certification that the hazmat employee has been trained and tested.
6. You have to give refresher training. Refresher training is required at least once every 3 years. Security awareness training must be provided at an employee’s next scheduled retraining at or within the 3-year training cycle. If the security plan for which training is required is revised during the 3-year recurrent training cycle, refresher training must be provided within 90 days of implementation of the revised plan.
7. Training tests do not have to be pass/fail. The regs do not state that an employee must “pass” a test. However, the employee may only be certified in areas in which he or she can successfully perform his or her hazmat duties.
8. You have to keep the records. A record of current training including the preceding 3 years must be created and retained for each hazmat employee for as long as the employee is employed by that employer and for 90 days thereafter.