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PHMSA training requirements
  • Hazmat employers must train their employees to fulfill PHMSA requirements, including procedures, safety, security, and function- and mode-specific requirements.

Hazmat training for each hazmat employee is one of the most important steps to take to ensure the safe movement of hazardous materials. The hazmat employer is responsible for training each hazmat employee to fulfill Pipeline and Hazardous Materials Safety Administration (PHMSA) requirements.

Training

A hazmat employee is an individual, including a self-employed individual, who during the course of employment performs any function subject to the Hazardous Materials Regulations (HMR). Before any hazmat employee performs any function subject to the HMR, the employee must be trained, tested, and certified by the hazmat employer. (172.702)

An employee may perform hazmat job functions before completing hazmat training, provided:

  • The employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee; and
  • The hazmat training is completed within 90 days of employment or change in job function. (172.704[c][1])

Training content

Hazmat employee training must include the following types of training:

  1. General awareness/familiarization. This training must provide familiarity with the regulations and enable the employee to recognize and identify hazardous materials. (172.704[a][1])
  2. Function-specific. This training must provide specific information on the regulations and special permits/exemptions that are applicable to the functions performed by the employee. (172.704[a][2])
  3. Safety. This training must provide information on hazmat emergency response information; measures to protect the employee from hazards to which they may be exposed, including measures implemented to protect the employee from exposure; and methods and procedures for avoiding accidents. (172.704[a][3])
    Employees who repair, modify, recondition, or test packagings may be excepted from safety training. (172.704[e])
  4. Security awareness. This training must provide 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. (172.704[a][4])
  5. In-depth security. Each hazmat employee of an entity that is required to have a security plan must be trained on the security plan and its implementation if they handle materials covered by the plan, perform a function related to the materials covered by the plan, or are responsible for implementing the plan. This training must include company security objectives, organizational security structure, specific security procedures, specific security duties and responsibilities for each employee, and specific actions to be taken in the event of a security breach. (172.704(a)(5))
  6. Modal specific. In addition to the above five types of training, modal-specific training requirements may be required for the individual modes of transportation (air, rail, highway, or vessel). (172.700[c]) For example, by highway, drivers must also be trained on the safe operation of the relevant motor vehicle(s) and the applicable requirements of the Federal Motor Carrier Safety Regulations. (177.816)