What Hazmat Employee Training Must Trucking Companies Provide under PHMSA Rules?

PHMSA's Hazardous Materials Regulations require each hazmat employer to train and test its hazmat employees. The training rules are in 49 CFR 172.700 through 172.704, and a trucking company that transports hazardous materials is a hazmat employer under 49 CFR 171.8. How DOT coverage works across agencies is explained in understanding DOT regulated.

Who is a hazmat employee. Under 49 CFR 171.8, a hazmat employee is a person employed full time, part time or temporarily by a hazmat employer who directly affects hazardous materials transportation safety. Self-employed owner-operators transporting hazardous materials are included. The term covers individuals who load, unload or handle hazardous materials, prepare them for transportation or operate a vehicle used to transport them.

Basic duty. A hazmat employer must train each hazmat employee and test each one by appropriate means on the training subjects (49 CFR 172.702(a) and (d)). A hazmat employee may not perform a regulated function unless instructed in the requirements that apply to it, subject to the initial training allowance below (49 CFR 172.702(b)).

Required training content (49 CFR 172.704(a)).

• General awareness and familiarization: familiarity with the HMR and the ability to recognize and identify hazardous materials.
• Function-specific: the requirements that apply to the functions the employee performs.
• Safety: emergency response information, measures to protect against workplace exposure, and methods for avoiding accidents, such as proper package handling.
• Security awareness: security risks and how to recognize and respond to possible threats. New hazmat employees receive this within 90 days after employment.
• In-depth security: for certain employees of companies required to have a security plan.

Driver training for trucking companies. No carrier may transport hazardous materials unless each hazmat employee who will operate a motor vehicle is trained in the applicable requirements of 49 CFR Parts 390 through 397 and safe vehicle operation, including pre-trip inspection, vehicle operation and load securement (49 CFR 177.816(a)). Drivers of a cargo tank, or of a vehicle with a portable tank of 1,000 gallons or more, receive specialized training and need the appropriate CDL (49 CFR 177.816(b)). A CDL with a tank vehicle or hazardous materials endorsement can satisfy these driver training requirements (49 CFR 177.816(c)). The inspection piece overlaps with the pre-trip and post-trip inspection rules.

Timing. A new or reassigned hazmat employee may perform functions before training only under direct supervision of a trained employee, and training must be completed within 90 days (49 CFR 172.704(c)(1)). Recurrent training is required at least once in each three-year period (49 CFR 172.704(c)(2)).

Records. The employer keeps a record of current training, covering the preceding three years, while the person is employed as a hazmat employee and for 90 days after. The record includes the employee's name, completion date, training materials, trainer and a certification of training and testing (49 CFR 172.704(d)). Rule changes such as those in PHMSA's international harmonization proposal can change training content.