When must you train your HazMat Employees:  How soon after employment begins, and how frequently must you provide refresher training?  Fortunately 49 CFR 172.704(c) provides answers to these questions.

First of all a new hire or one whose job function changes to become a HazMat Employee must receive HazMat Employee Training (see:  The Five Types of HazMat Employee Training) within 90 days.  And, they must be under the direct supervision of a properly trained and knowledgeable HazMat Employee until they receive training.

HazMat Employees must receive full recurrent training (not a refresher, but the full training) at least once every three years thereafter, ie. triennially.  The sole exception to this 3-year cycle is for HazMat Employees who require In-Depth Security Training.  Any time the Security Plan is revised, those HazMat Employees must be trained within 90 days of the implementation of the revised plan.

If your new employee received their HazMat Employee training with a former employer, their previous training will suffice as long as you obtain and maintain a current record of their training.

As the HazMat Employer you are responsible to ensure your HazMat Employees have been trained on the requirements of this part and tested by appropriate means.  You are also responsible for all of the requirements of the Hazardous Material Regulations (HMR) regardless of whether the required training has been completed.

If it’s been more than three years since your last HazMat Employee Training, or you’ve hired new HazMat Employees since your last training, or you’ve just lost track of when training was last completed, you should call me for a free consultation on your training needs.  While we’re talking we can discuss the training requirements of the EPA for your Hazardous Waste Personnel as well.