Training for hazmat employees

• All employees involved in the handling and transportation of hazardous materials must complete training.
• A record of current training, including the preceding three years, must be created and retained for each hazmat employee for the duration of employment, and for 90 days thereafter.

Employees who load, unload, or handle hazardous materials for transportation (including signing the hazardous waste manifest), are considered to be “hazmat employees” and must also be trained according to the Department of Transportation’s training requirements as well as the Environmental Protection Agency’s (EPA’s) training requirements.

49 CFR Part 172, Subpart H requires training for all employees involved in the handling and transportation of hazardous materials. The Hazardous Materials Regulations (HMR) require training be given by hazmat employers to all their hazmat employees regarding the safe transportation of hazardous materials. This includes emergency response.

A hazmat employee is an individual, including a self-employed individual, who, during the course of employment performs any function subject to the HMR. Before any hazmat employee performs any function subject to the HMR the hazmat employee must be trained, tested, and certified by the hazmat employer. Recurrent training is required once every three years.

However, if a new regulation is adopted or an existing regulation is changed, that relates to a function performed by a hazmat employee, that employee must be instructed on the new or revised regulations. This training must be completed before the employee performs the function and before the employee’s three-year recurrent training. The employee only needs to be instructed on the new or revised requirements.

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.

After completion of the training, each hazmat employer must certify, with appropriate documentation, that each hazmat employee received training and was tested on appropriate areas of responsibility. By requiring training, a hazmat employee’s awareness of safety considerations and regulatory requirements is increased, thereby reducing the occurrence of hazardous materials incidents caused by human error.

Training record

A record of current training, including the preceding three years, must be created and retained by the hazmat employer for each hazmat employee for the duration of employment, and for 90 days thereafter. The record shall include all of the following:

• The hazmat employee’s name;
• The most recent training completion date of the hazmat employee’s training;
• A description, copy, or the location of the training materials used;
• The name and address of the person providing the training;
• Certification that the hazmat employee has been trained and tested.