How do I identify which employees need hazmat training and what hazmat training they need?

Who must be trained under US law? (Do I need to do so-called CBTA Training?)

Each person who is identified as a “hazmat employee” (working for a “hazmat employer”) must be trained. These are people who directly affect the safety of a hazmat shipment in transportation including:

  • Anyone physically handling the shipment;
  • Anyone preparing paperwork, packaging, marking or labeling the shipment;
  • Anyone responsible for inspecting hazmat shipments or otherwise determining the “acceptability” of a shipment (this is typically called “acceptance training”).

At the end of this post, you can jump to our video on Competency Based Training and Assessment.

What are the time frames and other requirements for training?

In the United States, 49 CFR 172.700 is the law of the land when it comes to training. It requires as a minimum:

  • Training must occur within 90 days of employment in a hazmat employee position;
  • Recurrent training required no later than three years after initial training;
  • The IATA Dangerous Goods Regulations for air transport require training every two years;
  • Additional training is required whenever the job function or the regulations effecting your operation changes;
  • Maintenance of training records and certifications is required by all hazmat employers;
  • Employees of Part 121 and 135 US Airlines are required to train their employees every 12 months.

What are the DOT required training areas?

There are four main required training categories identified in the Hazmat Regulations (49 CFR, Part 172.700):

  • General Awareness Training;
  • Function Specific Training;
  • Safety Training;
  • Security Training.

Who is authorized to conduct the training?

Training may be provided by the hazmat employer or other public or private sources (49 CFR, 172.702):

  • The Hazmat Employer is ultimately responsible for training and certification of Hazmat Employees;
  • Third parties such as Transportation Development Group (TDG) LLC may also perform the required training.

What about so-called “Competency-Based Training and Assessment?”

Well, Jim Powell is an IATA Certified CBTA instructor and you can see his credentials and get more information here. However, the DOT doesn’t require anything other than what they’ve always required — each employee must be trained appropriately for their hazmat responsibilities. Period. In essence, that IS the heart of CBTA training. For more information click on the previous link.