IATA & IMO Training Requirements

Training Requirement Basics
All hazmat employees must be trained in the following areas dealing with dangerous goods, as required in IATA DGR 1.5 and IMDG Code 1.3.1.2.1 to 1.3.1.2.3 and 1.4:

General awareness training - provides familiarity with the regulatory requirements and allows employees to recognize hazardous materials in the workplace environment,
Function-specific training - detailed job-specific training in preparing, handling or transporting shipments of hazardous materials,
Safety training - includes emergency response and measures to be taken in case of an emergency or hazmat spill, and
Security training - security risks associated with dangerous goods transport and the enhancement of transportation safety.

Initial Training Requirements
IATA DGR regulatory guidelines for transporting dangerous goods by aircraft require training to be provided or verified upon the employment of personnel identified in Table 1.5 A of IATA's minimum requirements for training.

Shore-based personnel who are involved in the transport of dangerous goods intended to be shipped by sea should receive training reflective of their job function(s). While training is a recommendatory procedure and not required, vessel carriers often require proper IMDG training from shippers as a condition to accepting dangerous goods shipments.

Additionally, employers and employees involved with dangerous goods in the United States must adhere to the training requirements as described in Title 49, Code of Federal Regulations, Subpart H, governed by the U.S. Department of Transportation. For all modes and job functions, the following regulations apply (DOT 49 CFR §172.702):

It is the employer's responsibility to ensure their employees receive training,
The employee may not perform their duties unless they are under direct supervision of a properly trained and knowledgable hazmat employee, until they have received training,
Employees must be trained within 90 days of hire or change in job function(s),
The employer may provide training or use an outside source, and
The training must include a test.

Recurrent Training Requirements
Under the regulatory guidelines of the IATA DGR, recurrent training must take place within 24 months (two years) of previous dangerous goods training, unless a shorter time period is required by a competent authority. However, if recurrent training is completed within the final three months of previous training, dangerous goods certification extends from the date on which the recurrent training was completed until 24 months from the expiry date of that previous training.

For example, if your training certification expires on November 10, 2009 and you complete a recurrent training course for the IATA DGR within three months prior to November 10, 2009, your training certification has now been extended to November 10, 2011 (two years after your previous training completion date).

Since the IMDG Code does not reference a time period, the recurrent training period of three years from 49 CFR, Subpart H applies within the United States. Please consult with your local competent authority for all other countries.

Training Record Retention
A record of current training, including the last three years, must be kept and maintained for each hazmat employee while they remain an employee, and for a period of 90 days after the employee leaves(DOT 49 CFR §172.704(d)).

The following information must be kept in the record:

Hazmat employee's name,
Most recent training completion date,
Description, copy or location of training materials used to meet the requirements from paragraph §172.704(a),
Name and address of the person providing the training, and
Certification that the hazmat employee has been trained and tested.

For more information on IATA training requirements and our online and classroom courses, please email sales@bureaudg.com.

Fact:
The U.S. Department of Transportation's Hazmat Security Awareness Course is available for free online through Hazmat University.

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