Daniels Training Services

Recordkeeping Requirements of the US DOT for HazMat Employee Training

Recordkeeping Requirements of the US DOT for HazMat Employee Training

If you train your HazMat Employees triennially as required by US DOT regulations at 49 CFR 172, Subpart H; you are no doubt aware that in addition to training, §172.702(d) requires you to test them on the training requirements found in §172.704(a), these are:

  1. General Awareness/Familiarization
  2. Function Specific
  3. Safety/Emergency Response
  4. Security General Awareness
  5. In-Depth Security (if applicable)

§172.704(d) indicates the records that must be retained to document the successfully completed training:

  • The hazmat employee’s name;
  • The most recent training completion date of the hazmat employee’s training;
  • A description, copy, or the location of the training materials used to meet the requirements in paragraph (a) of this section;
  • The name and address of the person providing the training; and
  • Certification that the hazmat employee has been trained and tested, as required by this subpart.

Notice, there is no mention of the test itself; and indeed, it is not necessary to retain a copy of the test as a record of HazMat Employee training (10-0122).

But what could it hurt?  Why not retain the test with the remainder of the training documentation?  One word:  LITIGATION.  I’m no lawyer, but I’ve been told that if your training is the subject of a legal proceeding, the presence of even a single wrong answer on the test could be used to demonstrate your HazMat Employees were not properly trained.  So, what to do?

  1. Train and test your HazMat Employees triennially.
  2. Retain the records required by §172.704(d) and no more.  Be prepared to provide them if requested by the US DOT.
  3. Ensure that your HazMat Employees get the best training possible.

I can help with all of the above.  Attend one of my training workshops or contact me to provide on-site training for all of your HazMat Employees.  Either way you will receive high quality training at a good price.  And you can decide for yourself what to do with the test.