Often we get the question, “Who needs DOT hazmat training?” Not only are there nuances between the various agencies of DOT and the international transportation organizations DOT defers to, but often in companies there could be a number of people involved in the process – knowingly or unknowingly.
Basically, anyone involved in the process of sending hazardous materials (hazmat) will need to be trained. This would include anyone who:
- Purchases the packaging and/or determines it’s the correct packaging for your materials;
- Prepares the package for sending (boxes, labels, determines which box to use, etc.);
- Fills out the paperwork, choosing labels or choosing placards;
- Signs off on manifests or paperwork (including sending hazardous waste);
- Loads, unloads, and handles hazmat;
- Sells, tests, reconditions, repairs or modifies packaging for use in shipping hazmat;
- Screens baggage, cargo, or mail;
- Transports hazmat or operates a vehicle transporting hazmat;
- Is a freight forwarder who accepts/transfers/handles/unloads cargo; and,
- Anyone who supervises or conducts training for any of the above personnel.
Who Could be Involved?
So this could involve multiple departments or people at your company. Roles such as:
- Shipping & Receiving
- Mailroom Clerks
- Environmental, Health and Safety People
- Hazardous Waste Handlers/Manifest Signers
- Administrative Staff
- Procurement/Purchasing and Finance
- Plant Personnel
- Operations Management
Take a look at your process. Who’s involved? Do they need to be involved? Have they been trained?
DOT training is required by 49 CFR 100-185. 49 CFR regulates all hazmat shipments for the following agencies of the Department of Transportation:
- Pipeline and Hazardous Materials Security Administration (PHMSA)
- Federal Aviation Administration (FAA)
- Federal Motor Carrier Safety Administration (FMCSA)
- Federal Railroad Administration (FRA)
- State agencies with authority to enforce DOT regulations
Your training content is required to include general awareness, security awareness, safety and then function-specific training to the role each person is doing in the process. So the training durations could be different for different roles.
What if Someone Ships Hazmat For You?
Even if you have a third-party do the packaging for you, your company is still the shipper of record. That means anyone involved in the process from your end, even if it’s just one person signing paperwork that your vendor prepares, will need training. By signing paperwork, that employee is legally certifying the hazmat is properly packaged and ready for transport. This would apply to companies you use for hazardous waste transports, crate building, or freight forwarding.
Planes, Trains and Automobiles (and Ships)
If your packages are going by ground, that is, truck or train, you’ll need DOT training with refreshers every three years. There are additional railroad regulations that need to be covered if you’re shipping by rail.
If packages are going by plane, such as overnight service, you’ll need separate IATA training with refreshers every two years. Please note that unless you specify your hazmat as “ground only”, there’s a possibility it could be put onto an airplane. IATA has their own set of regulations in addition to the DOT, and air regulations are also covered in 49 CFR.
If packages are going on a ship, you’ll need IMDG training with refreshers every three years. This not only includes overseas shipments, but shipments to U.S. states such as Hawaii and Alaska or territories like Puerto Rico.
For more information about how the agencies work together, read our blog article, “Who Regulates Hazmat Shipments?”
If you need help sorting out who should be trained, or if you have employees you know need training or refreshers, contact us and we’d be happy to help! Check out our current hazmat shipping training schedule.