Click on the following topics to learn more about hazardous materials regulations pertaining to 49 CFR, IATA DGR and IMDG Code:
Do I need hazmat training?
For United States purposes, all hazmat employees (§171.8, 49 CFR
) who perform any of the following must be properly trained in the safe transportation of hazmat:
- Loads, unloads or handles hazardous materials,
- manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packagings as qualified for use in the transportation of hazardous materials,
- prepares hazardous materials for transportation,
- is responsible for safety of transporting hazardous materials, or
- operates a vehicle to transport hazardous materials.
The hazmat employer is responsible for providing this training, or may use a third-party trainer for this purpose. The U.S. DOT Hazardous Materials Regulations (HMR) does not offer any exemptions from hazmat training. Individuals who are self-employed and ship hazmat must be properly trained.
Those who transport or are involved with dangerous goods under IATA DGR and/or IMDG Code regulations must comply with the guidelines set forth for each respective authority of dangerous goods transport. While dangerous goods training is not mandatory for shippers of dangerous goods using the IMDG Code, it is often required by vessel carriers as a condition of accepting shipments of dangerous goods aboard their cargo ships.
As such, it is in everyone's best interests and highly recommended to take the appropriate hazardous materials and dangerous goods training courses to comply.
Hazmat training requirements
All hazmat employees within the United States must be trained in the following areas dealing with hazardous materials (§172.704(a) 49 CFR
, IATA 1.5.2
- General Awareness training: provides familiarity with the requirements and allows employees to recognize dangerous goods in the workplace,
- Function-specific training: detailed job-specific training,
- Safety training: includes emergency response and measures to be taken in case of an emergency at your workplace, and
- Security training: security risks associated with hazardous materials transportation and enhancement of transportation safety.
The following table provides a reference to hazardous materials and dangerous goods training requirements for each area of training under 49 CFR, IATA and IMDG regulations:
|General awareness and familiarization
* IATA DGR and IMDG Code regulations recommend that security awareness training be provided, but do not require it as part of a hazmat training curriculum.
The U.S. DOT does not require hazmat employees to be "certified" in the traditional sense that an electrician or an accountant would be certified to perform their job functions properly.
To complete a hazardous materials training curriculum, the following requirements must be satisfied for each hazmat employee:
- §172.702(d) – Successfully complete a test regarding the required areas of hazmat training in §172.704(a), and
- §172.704(d) – The hazmat employer must produce and retain a record of training for each hazmat employee currently employed, including their previous three years of training and 90 days after the hazmat employee has left.
Similarly, the IATA DGR requires that a test be taken to verify understanding of the regulations (18.104.22.168
) and a record of training be kept for a minimum of 36 months from the most current completion date and be made available upon request by an appropriate national authority (22.214.171.124
The IMDG Code does not specify the required aspects of dangerous goods "certification", but mentions that training records be kept by the employer and be provided to the employee upon request (126.96.36.199
Initial hazardous materials training
For United States purposes under 49 CFR, a new hazmat employee, or a hazmat employee who has changed job functions, may still perform their job functions prior to the completion of a hazardous materials training curriculum (§172.704(c)(1)
) provided that they are under the direct supervision of a properly trained and knowledgeable hazmat employee (§172.704(c)(1)(i)
). The training curriculum must also be completed within 90 days of employment or change in job function (§172.704(c)(1)(ii)
Under the IATA DGR regulations, initial training courses must be taken and maintained for:
- Freight forwarders
- Shippers of dangerous goods, including packers and persons and organizations undertaking the responsibilities of the shipper
Dangerous goods training must be provided or verified upon the employment of personnel concerned with the transport of dangerous goods and identified with the minimum subject matter mentioned in IATA DGR Table 1.5.A
Recurrent hazardous materials training
Each hazmat employee must repeat a full hazardous materials training curriculum at least once every three years (§172.704(c)(2), 49 CFR
), or whenever there has been a revision made by the United States Department of Transportation regarding the job functions, duties and responsibilities of a hazmat employee (§172.702(b), 49 CFR
). A test must be successfully completed and a record of the hazmat employee's recurrent training must be kept.
The following table summarizes recurrent training requirements with each mode of transportation:
|24 months / 2 years
|36 months / 3 years
* IMDG Code regulations do not specify the time period in which recurrent training must take place. As such, please consult your appropriate national authority for recurrent training requirements for vessel transport of dangerous goods. For United States purposes, this time period is every 3 years.
Record of training retention
The following table summarizes training record retention requirements for the regulations of each mode of transportation:
|Hazmat employee's name
|Most recent completion date of hazmat training
|Description, copy or location of training materials used to meet training requirements
|Name and address of training provider
|Certification or evidence that a test has been successfully completed
* IMDG Code regulations do not specify record retention requirements. Please consult your appropriate national authority for any applicable record retention requirements for dangerous goods training regarding vessel transport of dangerous goods.
Minimum training requirements, Table 1.5.A, IATA DGR
The following table summarizes the minimum training requirements for dangerous goods air transport under IATA DGR regulations:
|Aspects of transport of dangerous goods by air with which they should be familiar, as a minimum
||Shippers and packers
||Operators and ground handling agents
|Limitations||X|| ||X||X||X||X||X|| ||X||X||X||X
|General requirements for shippers||X|| ||X|| || ||X|| || || || || ||
|Classification||X||X||X|| || ||X|| || || || || ||X
|List of dangerous goods||X||X||X|| || ||X|| || || ||X|| ||
|General packing requirements||X||X||X|| || ||X|| || || || || ||
|Packing instructions||X||X||X|| || ||X|| || || || || ||
|Labeling and marking||X||X||X||X||X||X||X||X||X||X||X||X
|Shipper's Declaration and other relevant documentation||X|| ||X||X|| ||X||X|| || || || ||
|Acceptance procedures|| || || || || ||X|| || || || || ||
|Recognition of Undeclared Dangerous Goods||X||X||X||X||X||X||X||X||X||X||X||X
|Storage and loading procedures|| || || || ||X||X|| ||X|| ||X|| ||
|Pilots' notification|| || || || || ||X|| ||X|| ||X|| ||
|Provisions for passengers and crew||X||X||X||X||X||X||X||X||X||X||X||X
- Shippers and persons undertaking the responsbilities of shippers, including operator's staff acting as shippers, operator's staff
preparing dangerous goods as Company Materials (COMAT)
- Staff of freight forwarders involved in processing dangerous goods
- Staff of freight forwarders involved in processing cargo, mail or stores (other than dangerous goods)
- Staff of freight forwarders involved in handling, storage and loading of cargo, mail or stores
- Operator's and ground handling agent's staff accepting dangerous goods
- Operator's and ground handling agent's staff accepting cargo, mail or stores (other than dangerous goods)
- Operator's and ground handling agent's staff involved in the handling, storage and loading of cargo, mail
or stores and baggage
- Passenger and handling staff
- Flight crew members and load planners
- Crew members (other than flight crew members)
- Security staff who deal with the screening of passengers and their baggage and cargo, mail or stores, e.g. security screeners, their supervisors and staff involved in implementing security procedures