The requirement for initial and triennial training of HazMat Employees can be found within the Hazardous Materials Regulations (HMR) at 49 CFR 172, subpart H. Requirements include:

• Provide initial training within ninety (90) days of employment as a HazMat Employee or change of job function to those of a HazMat Employee.
• Prior to receiving initial training HazMat Employee must be under the direct supervision of a trained and knowledgeable person while performing the job function of a HazMat Employee.
• Recurrent training must be provided within three (3) years of the initial training date.
• HazMat Employee training must include the following:
  • General Awareness/Familiarization
  • Function Specific Responsibilities
  • Safety
  • Security General Awareness
  • In-Depth Security (if applicable)
  • Safe Driver (if applicable)
• HazMat Employee training must include a test.

What you may not know is that there are other training requirements specific to persons who transport HazMat by a particular mode of transportation.  These are identified below.

• 49 CFR 175.20: each HazMat Employee involved in the transportation by air of a HazMat must receive HazMat Employee training and the training required by 14 CFR parts 121 and 135.
• 49 CFR 177.800 and §177.816: each HazMat Employee that operates a motor vehicle over a public roadway for the transport of HazMat must receive HazMat Employee training as well as training on the following:
  • The requirements of §177.
  • The applicable regulations of the Federal Motor Carrier Safety Administration (FMCSA) for the operation of a commercial motor vehicle at §390 through §397.
  • Driver training must include the subjects specified at §177.816.

• 49 CFR 176.13: each HazMat Employee involved in the transportation of a HazMat by vessel must receive HazMat Employee training as well as receive training on the applicable requirements of §176.
• Interestingly, there are no modal-specific training requirements for the transportation of HazMat by rail within the HMR.

The above training is not required for those who ship or receive hazardous materials but is intended for those who take part in the HazMat transportation by the particular mode.  For example, the personnel at your shipping dock require solely HazMat Employee training while the truck driver who loads and transports the HazMat to its destination requires HazMat Employee training as well as the modal-specific training requirements of 49 CFR Part 177.