GUIDE TO DEVELOPING A

HAZMAT TRAINING PROGRAM

General Awareness, Function-Specific, Safety,
Security Awareness, and In-Depth Security Training.

WWW.PHMSA.DOT.GOV

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 1

 ACKNOWLEDGEMENTS

This guidance has been prepared based on a partnership agreement between the U.S. Department of Transportation,
Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Dangerous Goods Advisory Council (DGAC)
with input from the Dangerous Goods Symposium for Instructors and the hazmat community.
TABLE OF CONTENTS

PURPOSE   

HAZMAT REGULATORY REQUIREMENTS

SCOPE OF THE HAZARDOUS MATERIALS REGULATIONS   6

THE HAZARDOUS MATERIALS REGULATIONS’ TRAINING REQUIREMENTS   7

THE FIVE TYPES OF REQUIRED TRAINING   8

RECORDKEEPING REQUIREMENTS   
8

OTHER DOMESTIC AND INTERNATIONAL TRAINING REQUIREMENTS   9

HOW TO DEVELOP A TRAINING PROGRAM

DETERMINE WHO ARE YOUR HAZMAT EMPLOYEES   10

DETERMINE WHAT YOUR HAZMAT EMPLOYEES NEED   11

ASSESS YOUR TRAINING OPTIONS   12

ADVANTAGES AND DISADVANTAGES OF TRAINING OPTIONS   13

EVALUATE THE EFFECTIVENESS OF YOUR TRAINING   15

IMPLEMENTING BEST PRACTICES AND GUIDELINES

DEVELOP A SAFETY CULTURE   
16

DESIGNATE A TRAINING COORDINATOR   17

IMPLEMENT A PLANNING PROCESS   18

IMPLEMENT A CONSISTENT PROCESS FOR RECORDKEEPING   19

DEVELOP A TRAINING CURRICULUM   20

CHECKING YOUR PROGRAM FOR ACCURACY

DO YOU HAVE A TRAINING POLICY?   22

WHAT TYPE OF TRAINING IS PROVIDED?   23

WHERE IS THE TRAINING PROVIDED?   24

IS YOUR FUNCTION-SPECIFIC TRAINING ADEQUATE?   25

RESOURCES FOR MORE INFORMATION

LETTERS OF INTERPRETATION   26

TRAINING MATERIALS AND PUBLICATIONS   26

SEMINARS, WORKSHOPS, AND SPECIAL EVENTS   26

HAZMAT INFO-LINE   26

GLOSSARY
4
PURPOSE
The transportation of hazardous materials (hazmat) Hazmat incidents caused by human error can be reduced
underpins the American economy and our way of life. through the implementation of an effective training
We use oil and natural gas to heat and cool homes and program. An effective training program is a systematic
businesses, produce electricity, and provide raw materials method for providing training, which includes tests and
for plastics, fibers, paints, and other essential products. quizzes. It may consist of materials such as handouts,
We rely on chemicals to clean our water, fuel cars, overheads, videos, and exercises, as well as, interactive
construct buildings, fertilize crops, create medicines, computer-based training, tests and quizzes and, where
and manufacture clothing and many other essential there is an instructor, the instructor’s notes or course
commodities. While hazmat plays a critical role in our outline. The training program may be a tutored or self-
daily lives, the transportation of hazmat introduces some study course. The training provider may be the hazmat
inherent risks to the public, the environment, and property employer or an independent training provider.
that must be appropriately managed.
An effective training program:
Hazmat transportation is a process that involves people
performing functions related to handling, packaging,
• Develops a strong safety culture

storing, moving, loading and unloading of hazmat, and • Heightens employee safety by helping employees
responding to emergency situations while such materials protect themselves
are in transportation. It includes employees responsible • Improves a company’s effectiveness, efficiency,
for the safe transportation of hazmat. The process also and productivity
incorporates functions to design, manufacture, fabricate,
inspect, mark, maintain, recondition, repair, or test a
• Increases employee skills

package, container or packaging component used in • May prevent regulatory sanctions

transporting hazmat. With such a complex process, the • Aids in ensuring safe and secure shipment of hazmat
U.S. Department of Transportation (DOT) has identified
• Reduces likelihood of catastrophic event such as
human error as a contributing cause for most hazmat
fire aboard aircraft
transportation incidents.
• Provides employees with understanding of why
compliance and safety are necessary.
Human error may result from a variety of factors
including:
This guidance document explains the training
• Lack of knowledge leading to the mishandling of requirements in the Hazardous Materials Regulations
hazmat (HMR), identifies those employees who must be trained,
and provides a tool to help hazmat employers determine
• Lack of knowledge leading to undeclared shipments
what type of training and training environment may be
• Lack of awareness that hazmat is present best for their employees.
• Failure to follow established safety procedures

• Lack of understanding of one’s role during an

incident should one occur

• Lack of knowledge on how to respond to an incident

should one occur.

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 5

HAZMAT REGULATORY REQUIREMENTS

SCOPE OF THE HAZARDOUS MATERIALS REGULATIONS

The HMR (49 CFR Parts 100- 185), issued by the Department of Transportation’s Pipeline and Hazardous Materials
Safety Administration (PHMSA) under authority of the Federal hazardous materials transportation law (49 U.S.C. 5101 et
seq.), establish requirements governing the commercial transportation of hazmat by highway, rail, vessel, and air.

Under the HMR, hazmat are categorized by analysis and experience and assigned hazard classes and packing groups
based upon the risks they present during transportation. The HMR specify appropriate packaging and handling
requirements for hazmat, and require a shipper to communicate the material’s hazards through use of shipping papers,
package marking and labeling, and vehicle placarding. The HMR also require shippers to provide emergency response
information applicable to the specific hazard or hazards of the material being transported.

6
THE HAZARDOUS MATERIALS REGULATIONS’ TRAINING REQUIREMENTS
The HMR mandate training requirements for persons who prepare hazmat for shipment or who transport hazmat
in commerce. The intent of the regulations is to ensure that each hazmat employee is familiar with the HMR, is able
to recognize and identify hazmat, understands the specific HMR requirements applicable to the functions he or she
performs, and is knowledgeable about emergency response, self-protection measures, and accident prevention methods.
The regulations are performance based to provide a baseline set of training requirements while acknowledging the need
for flexibility due to the diversity of the hazmat workforce.

Training requirements are located in Subpart H of Part 172 of the HMR. The training requirements apply to hazmat
employers and hazmat employees as defined in §171.8. The HMR require all hazmat employees to be trained including
hazmat employers with direct supervision of hazmat transportation functions. Hazmat employer and hazmat employee
are defined as follows:

HAZMAT EMPLOYER means a person who uses one or more employees in connection with:

• transporting hazmat in commerce;

• causing hazmat to be transported or shipped in commerce; or

• representing, marking, certifying, selling, offering, reconditioning, testing, repairing, or modifying packagings
as qualified for use in the transportation of hazmat.

The term “hazmat employer” also includes any department, agency, or instrumentality of the United States, a State, a
political subdivision of a State, or Native American Indian tribe engaged in offering or transporting hazmat in commerce.
This term includes an owner-operator of a motor vehicle that transports hazmat in commerce.

HAZMAT EMPLOYEE means a person who is employed by a hazmat employer and who directly affects hazmat
transportation safety including:

• an owner-operator of a motor vehicle that transports hazmat;

• a person (including a self-employed person) who:

| loads, unloads, or handles hazmat;
| tests, reconditions, repairs, modifies, marks, or otherwise represents packagings as qualified for use in
the transportation of hazmat;
| prepares hazmat for transportation;
| is responsible for the safety of transporting hazmat; or
| operates a vehicle used to transport hazmat.

Training must be completed within 90 days of the first day of employment or the first day of a change in job function.
Until training is completed, a hazmat employee must be directly supervised by a person who has been trained. Further,
each hazmat employee must be provided with recurrent training at least once every three years. Each hazmat employee
must be tested upon completion of training. Training may be provided directly by the hazmat employer or by other
public or private sources. Regardless of who provides the training, the hazmat employer is responsible for ensuring
that appropriate testing occurs and that the training is effective, appropriate, and successful in achieving the intended
objectives of providing employees with the knowledge and skills necessary to perform their job functions safely.

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 7

THE FIVE TYPES OF REQUIRED TRAINING
GENERAL AWARENESS/FAMILIARIZATION TRAINING is training that provides familiarity with
the general requirements of the HMR, and enables the hazmat employee to recognize and identify hazmat. All hazmat
employees must receive general awareness training.

FUNCTION-SPECIFIC TRAINING is training that provides a detailed understanding of HMR requirements

applicable to the function(s) performed by the hazmat employee. Each hazmat employee must be trained on the specific
functions they are required to perform.

SAFETY TRAINING is training that covers the hazards presented by hazmat, safe handling, emergency response
information, and methods and procedures for accident avoidance. All hazmat employees must receive this training.

SECURITY AWARENESS TRAINING is training that provides a general understanding of the security risks
associated with hazmat transportation and the methods designed to enhance transportation security. This training
should include methods on how to recognize and respond to possible security threats. All hazmat employees must receive
this training.

IN-DEPTH SECURITY TRAINING is training that provides a detailed understanding of a company’s security
plan including company security objectives, specific security procedures, employee responsibilities, actions to take in the
event of a security breach and the organizational security structure. This training must be provided to hazmat employees
who handle or perform regulated functions related to the transportation of the materials covered by the security plan or
who are responsible for implementing the security plan.

RECORDKEEPING REQUIREMENTS
The hazmat employer is responsible for maintaining training records for each hazmat employee. These records must be
kept for the duration of the three-year training cycle while the hazmat employee is employed and for 90 days after the
employee leaves employment. Training records must be made available by the employer for audit and review by regulatory
authorities upon request.

Training records must include the following:

• The hazmat employee’s name

• The most recent training completion date

• A description of, copy of, or reference to training materials used to meet the training requirements

• The name and address of the person providing the training

• A certification that the person has been trained and tested as required

Certification that the hazmat employee has been trained and tested shall be made by the hazmat employer or a
designated representative. An example training record can be found in the Implementing Best Practices and Guidelines
section on p. 19.

8
OTHER DOMESTIC AND INTERNATIONAL TRAINING REQUIREMENTS
Employers should be aware that the HMR recognizes that other domestic and international agencies and organizations
also have training requirements. For example, the Federal Aviation Administration prescribes training requirements
for air carriers in the 14 CFR. Additionally, the International Maritime Dangerous Goods Code for vessel shipments;
Transport Canada TDG Regulations; and the International Civil Aviation Organization (ICAO) Technical Instructions for
air shipments also prescribe specific training requirements that are important because the HMR authorizes compliance
with these regulations.

Therefore, depending on a company’s operations, other training requirements in addition to the HMR may apply.
Relevant agencies and organizations may include:

• United States Federal Aviation Administration (FAA)

• United States Federal Motor Carrier Safety Administration (FMCSA)

• United States Federal Railroad Administration (FRA)

• United States Coast Guard (USCG)

• United States Occupational Safety and Health Administration (OSHA)

• United States Environmental Protection Agency (EPA)

• Transport Canada TDG regulations (TDG)

• International Maritime Organization (IMO)

• International Civil Aviation Organization (ICAO)

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 9

HOW TO DEVELOP A TRAINING PROGRAM

DETERMINE WHO ARE YOUR HAZMAT EMPLOYEES

Safe transportation of hazmat depends on proper preparation of the material for shipment and safe handling of the
material while it is being transported. Each hazmat employee must be aware of the hazards of such materials, their
potential for causing incidents and accidents, and how they should be safely prepared and transported.

The HMR require all hazmat employees to be trained, including those with hazmat responsibilities including pre-
transportation functions (see Glossary or 49 CFR §171.8) and those who supervise hazmat employees. For example,
a hazmat employee may be a person (including a self-employed person or an owner-operator of a motor vehicle) who:

• Determines the hazard class of hazmat

• Selects a hazmat packaging

• Places warning signs, blocks wheels, and sets brakes on tank cars placed for loading or unloading with closures
open

• Fills or loads a hazmat packaging

• Secures closures on filled hazmat packages or containers

• Marks a package to indicate that it contains a hazmat

• Labels a package to indicate that it contains a hazmat

• Prepares a hazmat shipping paper

• Provides and maintains hazmat emergency response information

• Reviews hazmat shipping papers to verify compliance with the HMR or international equivalents

• For persons importing hazmat into the United States, provides the shipper with information as to the requirements
of the HMR that apply to the shipment of the material while in the United States

• Certifies that hazmat is in proper condition for transportation in conformance with the requirements of the HMR

• Blocks and braces hazmat packages in a freight container or transport vehicle

• Segregates hazmat packages in a freight container or transport vehicle from incompatible cargo

• Selects, provides, or affixes placards for a freight container or transport vehicle to indicate that it is carrying hazmat

• Loads or unloads hazmat for the purpose of transportation

• Tests, reconditions, or repairs hazmat packaging

• Operates a vehicle used to transport hazmat

10
DETERMINE WHAT YOUR HAZMAT EMPLOYEES NEED
As previously mentioned, HMR training requirements are performance based to provide flexibility regarding training
format and delivery. Training may be provided directly by the hazmat employer or by independent training providers.
Therefore, hazmat employers have a variety of training options available.

The hazmat employer is responsible for selecting training that meets company safety goals and the HMR requirements.
The process may begin by conducting a needs assessment based on a thorough understanding of your company’s
operations and its hazmat employees’ responsibilities, knowledge and capabilities.

You may want to begin with these questions:

• What hazmat/wastes does your company handle and which hazards do they represent? For example, do your
hazmat employees handle hazmat such as infectious substances and lithium batteries?

• What quantities do you ship and how frequently? For example, do you ship bulk, non-bulk, excepted quantities, or
small quantities?

• What modes of transport do you use?

• Are there materials that your employees may not be aware are hazmat and are subsequently being shipped
undeclared? Examples include paint, perfume, batteries, aerosols, and fireworks.

• Where do you transport hazmat (i.e., domestic or international locations)?

• Do company accident or injury rates indicate additional training is necessary? If so, in what areas?

• What regulations does the training need to cover?

• What are the job descriptions/functions of your hazmat employees?

• Have your hazmat employees been previously trained?

• Are your hazmat employees trained in all aspects of the function(s) they are performing? For example, are your
employees responsible for shipper certification, i.e., trained in each aspect of the hazmat shipping that they are
certifying, such as packaging or package closure requirements?

• Have any responsibilities changed?

• Has the company’s operations changed?

• What languages need to be addressed?

• Are your employees aware of incident reporting requirements?

• Has anything else changed?

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 11

ASSESS YOUR TRAINING OPTIONS
After the needs assessment is complete, it is time to select a training tool. Potential selection criteria are content, method
of delivery, and instructor qualifications.

CONTENT should be easy to understand and appropriate for the audience. Sufficient time should be allocated to cover
the subject matter, and techniques should be used to ensure that students comprehend and retain the material presented.

A few questions hazmat employers might ask when assessing content include:

• Is the time allotted for training sufficient for employee comprehension?

• Is the information presented clearly and accurately and in a manner that can be understood by employees of
varying literacy and language skills?

• Does the training use repetition to confirm that key points are understood?

• Does the training use exercises, questions, or other mechanisms to ensure an understanding of what has been
taught?

• Is the information presented in a logical manner?

• Is comprehension tested?

• Is a test provided that allows the hazmat employee to demonstrate that they have satisfactorily completed training?

• Is there a follow-up support system? If so, what is it and does this system meet the need?

METHOD OF DELIVERY is another consideration for your training program. For purposes of this guidance,
training options have been broken down into four delivery methods:

• Web-based

• Computer-based

• Classroom

• Hands-on/Mentor training

Each delivery method has advantages and disadvantages.

INSTRUCTOR QUALIFICATIONS are an important element of an effective training program. Hazmat

instructors have varying degrees of subject matter expertise and teaching skills. In addition to understanding the subject
matter, instructors should understand the best method of delivery for the given audience.

12
ADVANTAGES AND DISADVANTAGES OF TRAINING OPTIONS
WEB-BASED TRAINING

ADVANTAGES DISADVANTAGES

Bandwidth limitations can place constraints on certain media

Provides standardized training ensuring a consistent message types

Hazmat employees must be self-directed and comfortable using

Decreases the time employees are out of the office the web

Allows for quick updates for rapidly changing material Hazmat employees may be distracted or interrupted

Training is more accessible to a larger audience Difficult to provide opportunities for hands-on experience

Cost effective way to refresh existing training Some may find it difficult to engage and retain

Training is more convenient for employees -- it is available Limited interaction with an instructor
anytime, anywhere

No travel costs Difficult to assess employee progress in real time

No costs associated with obtaining new media updates Compatible equipment may not be available

COMPUTER-BASED TRAINING

ADVANTAGES DISADVANTAGES

When there is a lot of video or complex graphics, computer-based Requires self-direction

training can ease download times and improve operations

Offers flexibility for the end-user; hazmat employees can simply Hazmat employees may be distracted or interrupted
load and run the training at their convenience

Cost effective way to refresh existing training It is difficult to provide opportunities for hands-on experience

Training is more accessible to a larger audience Minimal interaction with an instructor or subject matter expert

Hazmat employees can proceed at their own pace Information can become outdated

No travel costs Possible higher cost to update

Some may find it difficult to engage and retain

Compatible equipment may not be available

Difficult to assess employee progress in real time

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 13

CLASSROOM TRAINING

ADVANTAGES DISADVANTAGES

Potential personality differences between the trainer and the

Provides an instructor and a structured approach to teaching
hazmat employees
Allows for real-time discussion and provides interaction that Trainees can dictate the pace of training, leaving some students
isn’t easily duplicated even with the most advanced technology behind, and others bored with a pace that is too slow for them

Allows for constructive team building Difficult to guarantee outcomes

Personalized assistance from the instructor can address Scheduling based on trainer or facility availability, not employee
individual student needs needs

Leverages instructor skills and experience Costs for travel, training, and the instructor

Easy to confirm whether hazmat employees have taken the

course
Easy to use evaluation tools to confirm that learning has
occurred
Opportunity to customize training to meet employer needs and
requirements

HANDS-ON/MENTOR TRAINING

ADVANTAGES DISADVANTAGES

Simulates the job Can be high cost, high overhead

Provides hands-on experience allowing the hazmat employee to

Variables differ, so it’s difficult to guarantee outcomes
integrate theory and practice
Allows the employee to use critical thinking skills and problem- Timing based on mentor and/or facility availability, not
solving processes that incorporate professional knowledge necessarily employee needs
Provides a sense of urgency to develop alternatives and make
Potential personality differences
decisions under pressure without the possibility of consequences
Mentors gain more credibility with the employee since they have
A mentor must be available and capable of training
specific experience relating to the subject being taught

Procedural and policy gaps are identified

May avoid comprehension problems related to literacy/language

deficiencies

14
EVALUATE THE EFFECTIVENESS OF YOUR TRAINING PROGRAM
It is important to evaluate the effectiveness of the selected training tools against your expectations. Conducting an
evaluation allows you to improve the future planning and implementation of a training program, determine if training
objectives have been achieved, and proactively facilitate any necessary adjustments.

When conducting the evaluation, a few helpful questions include:

• Did the employee believe the training was effective and useful?

• What were the expectations of the training? Were these expectations met?

• After the training, is the employee proficient in performing job duties and responsibilities?

• Does the employee appear to need further training? If so, what functions need additional focus? Is this the result of
a deficiency in training?

Many techniques and tools can be used to evaluate training programs. A few methods of evaluating training are:

• Student opinion: Using employee feedback to help determine effectiveness of the training program including
identifying how to improve course content and delivery

• Supervisors’ observations: Using supervisor observations to assess an employee’s performance both before and
after the training

• On-the-job improvements: Assessing whether changes occur in job performance that result in changes in accident
rates, injury rates, or penalties

Regardless of the approach, if done correctly, you can use information derived from evaluations to help determine
whether training is effective and how to apply future training resources.

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 15

IMPLEMENTING BEST PRACTICES AND GUIDELINES

DEVELOP A SAFETY CULTURE

The HMR requires training for all hazmat employees; however, your training program should not stop once you have met
the HMR requirements. You and your managers should work with employees to develop a supportive safety culture that
encourages training as a continuous learning process.

You may want to consider implementing some or all of these measures:

• Visible promotion of a safety culture driven by top management

• Establish accountability for safety that begins with individual employees and includes all management layers

• Encourage employees to report safety issues or problems without fear of retribution or retaliation

• Encourage employees to identify new, improved ways to accomplish safety goals

• Monitor and evaluate employees as they perform their hazmat functions

• Correct potential issues as they are identified

• Provide opportunities for additional training

• Periodically reinforce safe practices through safety meetings

• Assess company safety performance through audits

• Consider implementing a monthly 10% hazmat inventory program wherein 10% of a company’s hazmat is spot
checked for proper packaging and hazmat communication each month. Implementing such a practice can help
detect potential errors

• Keep employees informed of assessments and results

• Review the results of incidents and inspections

• Regularly review regulatory changes and/or changes in company operations

Developing a safety culture is a continuous process, and the rewards are real. Employees take ownership of the
operations for which they are responsible and share responsibility equally with management for the overall safety of the
company. Enhanced safety measures help to reduce the cost of doing business by reducing accidents, decreasing workers’
compensation claims, and providing a more effective and targeted use of resources. Thus, companies and individuals
become more competitive while protecting people, property, and the environment.

16
DESIGNATE A TRAINING COORDINATOR
It is your responsibility to select training options that meet the requirements of the HMR and the needs of your hazmat
employees. This can be a challenging task, but it is extremely critical to ensuring that the training program you provide is
effective and successful.

One way to manage hazmat training is to designate one or more employees as training coordinators. Suggested
qualifications for training coordinators include:

• Knowledge of the HMR as they apply to company operations

• The ability to monitor and understand regulatory changes as they develop

• Knowledge of how to establish and manage a training program

• Experience in one or more of the hazmat duties being performed

Once a training coordinator(s) is in place, he or she can guide the training and development of each hazmat employee.
Suggested responsibilities include:

• Arranging for newly trained employees to be evaluated upon completion of a training program and periodically
thereafter

• Determining training needs for incumbents and assessing training options

• Consulting with other industry professionals on the best quality training available

• Instituting formal training evaluation programs and providing feedback to training providers

• Communicating on the status of training with management

• Providing feedback to training providers

• Maintaining training records in accordance with the HMR

A committee of trained hazardous materials employees may be established to provide guidance and assistance to the
training coordinator. Examples of potential committee responsibilities may include identifying training needs and
evaluating the effectiveness of training.

Training Coordinators often use checklists to record their progress during the development of a training program.
Examples of these checklists can be found in the Checking Your Program For Accuracy section on p. 22.

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 17

IMPLEMENT A PLANNING PROCESS
Implementing a planning process can help you develop a consistent approach for managing training needs. An example
planning framework is provided below to assist you in this process. The framework is not intended to be exhaustive or all-
inclusive, it is intended to help identify elements that could be considered.

DEFINE OBJECTIVES IMPLEMENT A TRAINING FRAMEWORK

Example Objective: Example Framework:

• Demonstrate support from all levels of leadership

Develop properly trained hazmat employees to meet
regulatory requirements for training, develop an educated • Identify point of contact(s) to manage training and
workforce, improve safety, and minimize the potential coordinate internally, as appropriate
negative impacts of hazmat on life, property, and the • Implement accountability
environment.
• Understand employee responsibilities, the tools they
use, and company operations
DEFINE GOALS
• Understand status of training to date
Example Goals: • Conduct a needs assessment to determine what
training is needed
• Reduce incidents and accidents
• Prioritize training needs
• Help employees protect themselves and the
environment • Assess the landscape of available training tools
and determine which tools meet the needs of the
• Improve a company’s effectiveness, efficiency, and
organization and its employees
productivity
• Execute training
• Develop a strong safety culture
• Evaluate training
• Prevent regulatory sanctions
• Maintain accurate training records to include:
• Heighten employee safety
| The hazmat employee’s name
• Increase employee skills
| The most recent training completion date
• Decrease property damage costs
| A description of, copy of, or reference to
• Help employees identify when hazmat are present
training materials used to meet the training
• Increase productivity requirements
| The name and address of the person
providing the training; and a certification
that the person has been trained and tested
as required

• Continuously improve the training program, as

necessary

18
IMPLEMENT A CONSISTENT PROCESS FOR RECORDKEEPING
The recordkeeping requirements in the HMR specify the content and retention rate of training records for each hazmat
employee, but do not specify the format for each record. Below is a sample training record to illustrate what a it may look
like.

HAZMAT EMPLOYEE TRAINING RECORD

General Awareness / Familiarization Training

Description, Copy, and Location of Training Trained By Date Trained Test / Score

Training Officer
Hazmat Training Introduction Video July 14, 2017 No Test
Janet
Training Officer
Hazmat Transportation Training Modules (On-line) July 14, 2017 On-line Test; 95%
Janet

Function-Specifc Training

Description, Copy, and Location of Training Trained By Date Trained Test / Score

Cylinder Requalification Instruction Book Supervisor Dan July 21, 2017 Written Test; 98%

Performance demonstration of Packaging, Marking and Labeling Live Demonstration

Supervisor Dan July 21, 2017
Checklist of tasks performed attached to this training record Test; 100%

Safety Training

Description, Copy, and Location of Training Trained By Date Trained Test / Score

Personal Safety Information Book Supervisor Dan July 14, 2017 Written Test; 100%

Security Awareness Training

Description, Copy, and Location of Training Trained By Date Trained Test / Score

Hazmat Transportation Security Awareness Training Module Training Officer July 28, 2017 On-line Test; 90%
(On-line) Janet

In-Depth Security Training

Description, Copy, and Location of Training Trained By Date Trained Test / Score

Company Security Plan and Risk Guidelines Binder Supervisor Dan July 28, 2017 Verbal Test; Passed

I certify that the hazmat employee identified on this training record has been trained and tested as required by the Hazardous
Materials Regulations, 49 CFR Part 172 Subpart H.

Employee Name: ______________________________ Signed:______________________________

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 19

DEVELOP A TRAINING CURRICULUM
The HMR mandate five types of training. The HMR do not prescribe in detail what topics to address during each type of
training. To assist in evaluating your company’s training needs, a list of the types of training with possible curriculums is
provided here. These lists are not intended to be exhaustive or all inclusive.

GENERAL AWARENESS/FAMILIARIZATION provides hazmat employees with familiarity with the

requirements of the Hazardous Materials Regulations and enables hazmat employees to recognize and identify hazmat.
All hazmat employees are required to have general awareness/ familiarization training. This training typically provides a
basic understanding of:

• The Identification of Hazardous Materials • Shipping Papers

• The Hazard Classification System • Segregation

• How to Use the Hazardous Materials Table • Understanding of the HMR Training Requirements

• Packaging • Requirements for Incident Reporting

• Markings and Labels • Security

• Placards

FUNCTION-SPECIFIC provides hazmat employees a detailed study of the requirements of the regulations
applicable to the function(s) for which the person is responsible. Training needs will depend on the company operations
and the hazmat employee’s responsibilities. Your responsibility is to identify the specific topics and extent to which topics
are covered to meet your employees’ needs.

Examples of function-specific topics are included within the Function-Specific Knowledge Checklist on p. 25.

20
SAFETY TRAINING covers the hazards presented by hazmat, safe handling, emergency response information, and
methods and procedures for accident avoidance. Training that meets EPA and OSHA regulations may be acceptable in
meeting the HMR. All hazmat employees are required to have safety training. Topics may include:

• Emergency Response Information • Respiratory Protection

• Emergency Response Telephone Numbers • Fire Protection

• Means of Egress • Fire Brigades

• Employee Emergency Plans and Fire Prevention Plans • Portable Fire Extinguishers

• General Safety and Health Provisions • Fixed Extinguishing Systems

• Employee Emergency Action Plans • Fire Detection Systems

• Bulk Delivery and Mixing Vehicles • Employee Alarm Systems

• Contract Employer Responsibilities • Materials Handling and Storage

• Mechanical Integrity • Moving the Load

• New Technology Programs • Crawler Locomotives and Truck Cranes

• Personal Protective Equipment • Electrical Safety-Related Work Practices

• Hazardous Waste Operations and Emergency • Confined and Enclosed Spaces

Response
• Precautions Before Entering

SECURITY AWARENESS TRAINING provides hazmat employees with a general understanding of the
security risks associated with hazmat transportation and the methods designed to enhance transportation security. All
hazmat employees are required to have security awareness training. Examples of subjects that could be included are:

• Regulatory Requirements

• Potential Threats

• Potential Targets

• Prevention Tools

IN-DEPTH SECURITY TRAINING directly relates to the required company security plan. Specific content is
dependent upon the company security plan and employee responsibilities. Hazmat employees are required to receive
training commensurate with their responsibilities. Training must include:

• Security Objectives

• Specific Security Procedures

• Employee Responsibilities

• Actions to Take in the Event of a Security Breach

• Organizational Security Structure

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 21

CHECKING YOUR PROGRAM FOR ACCURACY

DO YOU HAVE A TRAINING POLICY?

The hazmat employer is responsible for selecting training that meets company safety goals and the HMR requirements.
Although not required by the HMR, many companies establish training policies or standard operating procedures to
help with decision-making. Checklists can be used as tools to assist with understanding the status of training efforts and
decision-making.

Below is an example of a checklist that can help you to identify elements of your training policy. Rows have been left blank
so that you can identify criteria not listed that is included in your company training policy.

TRAINING POLICY CHECKLIST YES NO

Do you have a training policy? □ □

If yes, what does it include?

• Purpose and scope □ □

• A definitions section □ □
• Identification of employees that require training □ □
• A list of employee functions and responsibilities □ □
• Identification of the type of training required □ □
• Initial training requirements □ □
• Recurrent training requirements □ □
• Function-specific or company-specific □ □
• Testing (pass/fail) requirements □ □
• Record keeping requirements □ □
• Certification of training requirements □ □
• Training as needed (i.e., when regulations are updated or issued) □ □
• Training every year □ □
• Training every 2 years □ □
• Training every 3 years □ □

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WHAT TYPE OF TRAINING IS PROVIDED?
Below is an example of a checklist to help you determine what additional training your employees might need. Rows have
been left blank so you can identify topics not listed that are important to your company.

TRAINING PROGRAM CHECKLIST YES NO

What type of training is provided to your employees?

• Classroom (In-house or external) □ □

• Computer-based □ □
• Web-based □ □
• Hands-on/Mentor □ □
What topics are included in your program?

• General Awareness □ □
• Classification □ □
• Documentation □ □
• Packaging □ □
• Marking □ □
• Labeling □ □
• Placarding □ □
• Loading & Unloading (non-bulk) □ □
• Loading & Unloading (bulk) □ □
• Blocking & Bracing □ □
• Security Awareness □ □
• In-Depth Security Awareness □ □
• Safety □ □
• Segregation □ □
• Incident Reporting □ □
• Operations □ □
• Packaging □ □

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 23

WHERE IS THE TRAINING PROVIDED?
It is important to evaluate the benefits of training programs as they relate to your company’s needs. Below is an example
of a checklist and criteria that can assist you with this evaluation. Rows have been left blank so you can include additional
criteria that are important to your company.

TRAINING LOCATION CHECKLIST IMPORTANT NEUTRAL UNIMPORTANT

Commercially available programs off-site

• Knowledge/reputation of instructor □ □ □
• Reputation of training organization □ □ □
• Location of training □ □ □
• Length of time employee will be absent from job □ □ □

Commercially available programs for in-house training

• Knowledge/reputation of instructor □ □ □
• Reputation of training organization □ □ □
• No interruptions while employees are in training □ □ □
• Length of time required to complete program □ □ □

Company-provided in-house instruction

• Availability of knowledgeable instructor □ □ □

• No travel costs □ □ □
• Length of time required to complete program □ □ □
• No interruptions while employees are in training □ □ □
• Combined instructor and computer-based training □ □ □

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IS YOUR FUNCTION-SPECIFIC TRAINING ADEQUATE?
The following checklist is provided to assist you in identifying the types of training needed to satisfy function-specific
training requirements. This checklist is not intended to be exhaustive or all-inclusive. It is the employer’s responsibility to
determine which topics require in-depth coverage to enable their employees to perform their hazmat duties safely.

FUNCTION-SPECIFIC KNOWLEDGE CHECKLIST

Hazard Classification Placards

□ Definition of the Nine Hazard Classes □ Requirements
□ Class 1: Explosives □ Table 1 and Table 2
□ Class 2: Gases □ Exceptions to Placard Tables
□ Class 3: Flammable and Combustible Liquids □ How Placards Convey Hazard
□ Class 4: Flammable Solid, Spontaneously Combustible, □ Color
Dangerous When Wet □ Symbols
□ Class 5: Oxidizer, Organic Peroxide □ Text
□ Class 6: Poisonous or Toxic, Infectious Substances □ Hazard Class Number or Division Number
□ Class 7: Radioactive □ Placard Placement Requirements
□ Class 8: Corrosives □ Use of International Placards
□ Class 9: Miscellaneous
Shipping Papers
Hazardous Materials Table □ Define Shipping Papers
□ Appendix A □ Identify Information Required and Display
□ Appendix B □ Basic Description and Sequence
□ Special Provisions □ Additional Information
□ Emergency Response Telephone Number
Packaging Selection □ Emergency Response Information
□ Packing Group Definition □ Certification by Shipper
□ Packing Group I (PGI) □ Identify Retention Requirements
□ Packing Group II (PGII)
□ Packing Group III (PGIII) Operations
□ Exceptions for Packing Group Assignments □ Highway
□ Air
□ Packaging Manufacturing □ Rail
□ Vessel
□ Packaging Retesting
Segregation
Markings □ Highway
□ Basic and Additional Markings on Non-Bulk Packaging □ Air
□ Markings for Bulk Packaging □ Rail
□ Vessel
Labels □ Warehouse (storage)
□ Hazard Labels and Placement
□ Primary Hazard Label Handling
□ Subsidiary Hazard Label □ Loading and Unloading
□ How Labels Convey Hazard □ Filling
□ Color □ Blocking and Bracing
□ Symbols
□ Text Incident Reporting Requirements
□ Hazard Class Number or Division Number □ By Telephone
□ In Writing

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 25

RESOURCES FOR MORE INFORMATION

LETTERS OF INTERPRETATION
The Pipeline and Hazardous Materials Safety Administration, Office of Hazardous Materials Safety (OHMS) provides
written clarifications of the Hazardous Materials Regulations in the form of interpretation letters. These letters reflect
the agency’s current application of the HMR to the specific facts presented by the person requesting the clarification.
Interpretations are one form of Guidance provided by OHMS.

Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how
to comply with the HMR. OHMS regularly reviews interpretations for accuracy and applicability. Interpretation letters
from the last ten years are published to provide the public with a greater awareness and understanding of the HMR.

To access letters of interpretation on line, visit: https://www.phmsa.dot.gov/regulations/title49/b/2/1

TRAINING MATERIALS AND PUBLICATIONS

Training, outreach, and information dissemination are important responsibilities of PHMSA. To promote compliance
with the HMR, PHMSA develops brochures, charts, publications, training modules, videos and other safety-related
information and makes them available to the public through the PHMSA website. Many of the publications spotlight
safety concerns such as lithium batteries, undeclared hazmat shipments, wetlines, and alternative fuels such as ethanol.

To order training materials and publications, visit: https://www.phmsa.dot.gov/training/hazmat/publications

SEMINARS, WORKSHOPS, AND SPECIAL EVENTS

PHMSA offers free seminars, workshops, and special events throughout the year. These free training events are for
anyone who offers or transports hazmat in commerce, provides emergency response to accidents or incidents involving
hazmat, or desires to learn more about the HMR.

To learn about upcoming training events, visit: https://www.phmsa.dot.gov/hazmat/seminars/seminars-and-workshops

HAZMAT INFO-LINE
Call our Hazmat INFO-LINE: 1-800-467-4922 to obtain hazmat transportation information and copies of rulemakings.
Specialists are on duty Monday through Friday from 9 a.m. to 5 p.m. Eastern time. You may call any time, 24 hours a day,
seven days a week, and leave a message. We will return your call before the end of the next business day. You may also use
this number to report alleged violations of the Hazardous Materials Regulations.

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PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 27
GLOSSARY

Hazmat Employee Hazmat employee means a person who is:

(i) Employed on a full-time, part time, or temporary basis by a hazmat employer and
who in the course of such full time, part time, or temporary employment directly
affects hazmat transportation safety;
(ii) Self-employed (including an owner-operator of a motor vehicle, vessel, or
aircraft) transporting hazmat in commerce who, in the course of such self-
employment, directly affects hazmat transportation safety;
(iii) A railroad signalman; or
(iv) A railroad maintenance-of-way employee.

This term includes an individual employed on a full time, part time, or temporary
basis by a hazmat employer, or who is self-employed, who during the course of
employment:
(i) Loads, unloads, or handles hazmat;
(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions,
repairs, or tests a package, container or packaging component that is represented,
marked, certified, or sold as qualified for use in transporting hazmat in commerce;
(iii) Prepares hazmat for transportation;
(iv) Is responsible for safety of transporting hazmat; or
(v) Operates a vehicle used to transport hazmat.

Hazmat Employer Hazmat employer means:

A person who employs or uses at least one hazmat employee on a full-time, part
time, or temporary basis; and who:
(i) Transports hazmat in commerce;
(ii) Causes hazmat to be transported in commerce; or
(iii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions,
repairs or tests a package, container, or packaging component that is represented,
marked, certified, or sold by that person as qualified for use in transporting hazmat
in commerce; or

A person who is self-employed (including an owner-operator of a motor vehicle,

vessel, or aircraft) transporting materials in commerce; and who:
(i) Transports hazmat in commerce;
(ii) Causes hazmat to be transported in commerce; or
(iii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions,
repairs or tests a package, container, or packaging component that is represented,
marked, certified, or sold by that person as qualified for use in transporting hazmat
in commerce; or

28
GLOSSARY

A department, agency, or instrumentality of the U.S. Government or an authority of

a State, political subdivision of a State, or Native American Indian tribe; and who:
(i) Transports hazmat in commerce;
(ii) Causes hazmat to be transported in commerce; or
(iii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions,
repairs or tests a package, container, or packaging component that is represented,
marked, certified, or sold by that person as qualified for use in transporting hazmat
in commerce.

Pre-Transportation Function A function specified in the HMR that is required to assure the safe transportation of
hazmat in commerce, including:
(1) Determining the hazard class of hazmat.
(2) Selecting a hazmat packaging.
(3) Filling a hazmat packaging, including a bulk packaging.
(4) Securing a closure on a filled or partially filled hazmat package or container or on
a package or container containing a residue of hazmat.
(5) Marking a package to indicate that it contains hazmat.
(6) Labeling a package to indicate that it contains hazmat.
(7) Preparing a shipping paper.
(8) Providing and maintaining emergency response information.
(9) Reviewing a shipping paper to verify compliance with the HMR or international
equivalents.
(10) For each person importing hazmat in the United States, providing the shipper
with timely and complete information as to the HMR requirements that will apply to
the transportation of the material within the United States.
(11) Certifying that hazmat is in proper condition for transportation in conformance
with the requirements of the HMR.
(12) Loading, blocking, and bracing a hazmat package in a freight container or
transport vehicle.
(13) Segregating a hazmat package in a freight container or transport vehicle from
incompatible cargo.
(14) Selecting, providing, or affixing placards for a freight container or transport
vehicle to indicate that it contains hazmat.

Training Program A systematic method that has been developed for providing training, which consists
of associated material (such as handouts, overheads, videos, exercises, etc., as well
as use of interactive computer-based training), tests and quizzes and, where there is
an instructor, the instructor’s notes or course outline. The training program may be
a tutored or self-study course.

PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 29

GLOSSARY

In-House Training Training provided to the employees of a company by a company employee or an

independent training provider at the company facility.

Training Provider Any person or organization that offers or provides hazmat training, including a
hazmat employer.

Independent Training Provider A person or organization, independent of a hazmat employer, that offers hazmat
training.

Recurrent Training Training given at intervals (usually not more than two or three years) to provide an
update on regulatory changes to ensure a hazmat employee’s knowledge remains at
the required level to safely carry out their responsibilities.

Safety Training Training that covers the hazards presented by hazmat, safe handling, emergency
response information and methods and procedures for accident avoidance.

Security Awareness Training Training that is intended to provide a general understanding of the security risks
associated with hazmat transportation and the methods designed to enhance
transportation security. It should identify possible practical indicators of a potential
security threat.

In-Depth Security Training Training related to a company’s required security plan. It should cover company
security objectives, specific security procedures, employee responsibilities, actions
to take in the event of a security breach and the organizational security structure.

30
 For additional information contact:

The Hazardous Materials Info Center

1-800-HMR-4922

(1-800-467-4922)

E-mail: infocntr@dot.gov

http://phmsa.dot.gov

Pipeline and Hazardous Materials Safety Administration

Outreach, Engagement, and Grants Division

East Building, 2nd Floor

1200 New Jersey Ave., SE

Washington, DC 20590

Email: training@dot.gov

202-366-4900

202-366-7342 (Fax)

PHH50-0173-1018