Looking at Hazmat Training as Addressed in DOT Letters of Interpretations

摘要

Ed. Note: Over 3,300 letters of interpretation going back to 1993 as well as over 300 comments by our Technical Advisors on select letters can be found at hazmatship.com. After logging in, browse to US DOT / Letters of Interpretation or perform a search in subscriber content. The basic requirements of the Hazardous Materials Regulations (HMR) for training of hazmat employees seem rather straightforward at first glance. In the simplest terms (i.e., ignoring all the ifs, ands, and buts), the requirements are: 1. A hazmat employer must ensure that each hazmat employee is trained in accordance with the requirements prescribed in the HMR (§§ 173.1(b) and 172.702(a)); 2. A hazmat employee may not perform any function subject to requirements of the HMR unless instructed in those requirements (§ 172.702(b)); 3. Training may be provided by the hazmat employer or other public or private sources (§172.702(c)); 4. Hazmat employees must be trained and tested in the subjects covered in § 172.704, i.e., general awareness/familiarization training, function-specific training, safety training, security awareness training, and in-depth security training (§ 172.704(a)(l) through (5)). 5. Both initial training within 90 days after employment and recurrent training at least once every three years are required (§ 172.704(c)). 6. A record of training must be created and retained, to include a certification that the employee has been trained and tested (§ 172.704(d)).