Hazmat Housekeeping: Should I Keep the Training Test?
The US DOT’s hazmat training standard for “hazmat employees” includes a specific provision that requires employers to certify that the hazmat employee has been “trained and tested, as required by this subpart.” [49 CFR 172.704(d)(5)] To satisfy the “test” requirement, employees can take a written test, a performance test, or a web-based test. Hazmat employers often wonder: Is a copy of the test requried to prove to DOT that your employee has met the hazmat training standard?
The employers’ record of hazmat employee training must include the following elements:
As for the test, employers may record employees’ completion of the hazmat test in a number of ways, provided that the requirements of §172.704(d) are satisfied:
A common question for hazmat employers is whether the test itself should be kept as part of the employee’s hazmat training record. If you look at the list of required elements of a hazmat training record above, you’ll notice that there is no reference to keeping a copy of the test taken.
In a 2010 letter of interpretation, PHMSA made it clear that the hazmat employer is not responsible for keeping a copy of the test.
The HMR does require only that all hazmat employees are “trained and tested” and that employers keep records of training to ensure the employees are competent to prepare hazmat shipments.
Is the Certificate from My Trainer Enough?
A Certificate of Achievement received from a training provider may meet the requirements as a record of training. However, it is ultimately the employers’ responsibility to “certify” that hazmat employees have been trained in line with DOT standards. Employers should verify that the certificate provided includes each of the five elements above. If the certificate is missing any of these elements, the employer should add it or create a separate training record in order to meet the 49 CFR 172.704(d) requirements.
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The employers’ record of hazmat employee training must include the following elements:
- Employee name
- Most recent hazmat training completion date
- Description, copy, or location of training materials used to meet the requirements
- Name and address of the person providing the training
- Certification that the employee has been trained and tested in accordance with 49 CFR 172, Subpart H
As for the test, employers may record employees’ completion of the hazmat test in a number of ways, provided that the requirements of §172.704(d) are satisfied:
- Written certificate
- Electronic computer file
- Index card
- Written documentation of tasks performed or answers given
- Notebook entry
A common question for hazmat employers is whether the test itself should be kept as part of the employee’s hazmat training record. If you look at the list of required elements of a hazmat training record above, you’ll notice that there is no reference to keeping a copy of the test taken.
In a 2010 letter of interpretation, PHMSA made it clear that the hazmat employer is not responsible for keeping a copy of the test.
The HMR does require only that all hazmat employees are “trained and tested” and that employers keep records of training to ensure the employees are competent to prepare hazmat shipments.
Is the Certificate from My Trainer Enough?
A Certificate of Achievement received from a training provider may meet the requirements as a record of training. However, it is ultimately the employers’ responsibility to “certify” that hazmat employees have been trained in line with DOT standards. Employers should verify that the certificate provided includes each of the five elements above. If the certificate is missing any of these elements, the employer should add it or create a separate training record in order to meet the 49 CFR 172.704(d) requirements.
Nationwide Hazmat Workshops for Industry Pros
Build the expertise and confidence to ship hazmat safely and in compliance with the latest 49 CFR, IATA, and IMDG rules. The Complete Multimodal Hazmat Shipper Workshops are presented in convenient locations nationwide. Enroll now and get 365 days of complete on-the-job support, including access to the Finder Q&A service!
Join experienced hazmat professionals from your area for an engaging learning experience led by instructors who help uncover the real-world meaning of the regulations that affect your job.
Tags: DOT, hazmat shipping, training
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