On March 13th, 2024 the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a series of frequently asked questions (FAQs) related to hazardous materials training. These FAQs have been published as part of PHMSA’s initiative to convert historical letters of interpretation (LOI) applicable to hazmat regulations into easy-to-understand questions and answers.
PHMSA believes that these FAQs can help hazmat personnel understand the regulatory requirements better and ensure 100% compliance. This is the third set of FAQs published by PHMSA. The previous two FAQs focused on the applicability of the Hazardous Materials Regulations and incident reporting requirements respectively.
Here is an overview of the FAQs related to hazardous materials training:
What are the Hazardous Materials Training Requirements?
Any person or entity that meets the definition of a hazmat employee under §171.8 is required to undergo training in accordance with §172.700. It is the responsibility of the hazmat employer to provide training to their employees, assess their skills and knowledge, certify their training, and maintain all the records related to their training.
A trained hazmat employee must be aware of the general provisions of the Hazardous Materials Regulations (HMR), must be able to identify hazardous materials, and must be familiar with the specific regulatory requirements applicable to their job-related functions.
What are the Required Components of a Complete Hazmat Training Program?
According to §172.704, a complete hazmat training program must contain the following components.
- General awareness training
- Function-specific training
- Safety training
- Security awareness training
Apart from this, companies that maintain a security plan are required to provide their employees with appropriate security training.
In addition to that, employees should also undergo mode-specific training – depending on the mode of hazmat transportation they are involved in.
Who is a Hazmat Employee?
According to §171.8, a hazmat employee is someone whose job-related functions impact the safety of transporting hazardous materials. Common job-related functions that can impact hazmat transportation safety include – but are not limited to – loading, unloading, and handling hazardous materials, inspecting hazmat packaging, preparing shipments of hazardous materials, and operating vehicles used in the transportation of hazardous materials.
Who is a Hazmat Employer?
According to §171.8, a hazmat employer is a person or entity that uses one or more hazmat employees (as defined in the same section) for the following purposes.
- Transporting hazardous materials in commerce
- Arranging for hazardous materials to be transported in commerce
- Engaging in activities related to the design, manufacturing, fabrication, inspection, marking, maintenance, reconditioning, testing, or repairing containers, drums, or packagings that can be used for hazmat transportation.
Can a Hazmat Employee Self-Train?
Yes, they can self-train – as long as their training meets the training, testing, certification, and recordkeeping requirements specified under §172.704.
Has PHMSA Set Any Minimum Qualifications or Other Criteria for Hazmat Trainers?
No. PHMSA has not set any eligibility criteria for hazmat trainers. The only requirement is that a trainer must be able to provide a level of training that meets the training requirements specified under §172.704.
What are the Recordkeeping Requirements for Hazardous Materials Training?
According to §172.704(d), hazmat employers are required to maintain training records for all hazmat employees. The records can be in physical or electronic form. They must contain the following information.
- The hazmat employee’s name
- Date on which they completed training
- Information about the training materials
- Name and contact information of the trainer
- A certification that the employee’s training and testing requirements have been met in accordance with the relevant provisions of the HMR
Can a Hazmat Employee Have Their Training Requirements Waived If They Can Pass a Test on the Hazmat Regulations Related to Their Job Duties?
No. Training requirements for hazmat employees cannot be waived under any circumstances. Anyone who meets the definition of a hazmat employee must undergo initial as well as recurrent training that covers all the regulatory requirements related to their job.
Meet Your Compliance Requirements with Hazmat University’s Online Hazardous Materials Training Courses
Hazmat University offers a comprehensive suite of online training courses that cover all the regulatory requirements for hazardous material transportation by ground, air, and vessel. Whether you need mode-specific training or multimodal training, whether you are looking for initial or recurring training, we have what you need.
Our online courses offer flexibility and allow you to learn at pace that you feel comfortable with. Our user-friendly interface and interactive learning exercises are designed to ensure maximum engagement and retention.
Our training courses are not just about regulatory compliance. They are designed to equip you with the knowledge and practical skills you need to handle hazardous materials safely and confidently. Call us today at 844-427-0167 or use our online contact form to find out more about our hazmat training courses.
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