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Training
  1. May a hazmat employer/employee train and test himself or herself (e.g., owner-operator)?
  2. Who certifies that an instructor is qualified to train, test, and certify in accordance with § 172.704?
  3. Does the trainer who teaches and tests the hazmat employee certify that the hazmat employee is trained/tested?
  4. Must the test be in a written format or may a skill demonstration be used?
  5. Must the employee "pass" a test?
  6. Does IMDG Code, ICAO Technical Instructions, OSHA or EPA training fulfill the HMR requirements?
  7. Does a Commercial Driver's License (CDL) with a hazmat endorsement satisfy the training requirements under the HMR?
  8. Do the HMR training regulations apply to foreign flag vessels carrying hazardous materials?
  9. Do the HMR training regulations apply to a hazmat employer and employees who operate a bulk vessel transporting hazardous materials?

  1. May a hazmat employer/employee train and test himself or herself (e.g., owner-operator)?

    A. Yes, self-training is acceptable provided that all training requirements of § 172.704 are met, including maintaining records of current training.

  2. Who certifies that an instructor is qualified to train, test, and certify in accordance with § 172.704?

    A. There is no requirement for certification of trainers required under Subpart H of Part 172. The employer must determine whether a trainer is qualified to provide the required training.

  3. Does the trainer who teaches and tests the hazmat employee certify that the hazmat employee is trained/tested?

    A. The hazmat employer is responsible for certifying that the employee has been trained and tested. However, a hazmat employer may designate an outside source to train, test, and certify on its behalf. See § 172.704.

  4. Must the test be in a written format or may a skill demonstration be used?

    A. Any test that ensures that the employee can perform the assigned duties in compliance with the HMR is acceptable. Training and testing may be accomplished in a variety of ways: performance, written, verbal, or a combination of these. See § 172.702(d).

  5. Must the employee "pass" a test?

    A. The requirements do not state that the employee must "pass" a test; however, an employee may only be certified in areas in which he/she can successfully perform his or her hazmat duties. See § 172.702(b).

  6. Does IMDG Code, ICAO Technical Instructions, OSHA or EPA training fulfill the HMR requirements?

    A. This training often includes general awareness, function specific, and safety subject matter; however, the hazmat employer must ensure that the training and testing requirements of the HMR are met. Portions of these categories not covered and any other training requirements (e.g., security awareness training) will require additional training. See § 172.704(b).

  7. Does a Commercial Driver's License (CDL) with a hazmat endorsement satisfy the training requirements under the HMR?

    A. Compliance with requirements for a CDL with a hazardous materials endorsement provides a driver with the general knowledge and skills necessary to safely operate a commercial motor vehicle with hazardous materials cargo and may satisfy some of the training requirements of the HMR (see §§ 172.704 and § 177.816). Additional training may be required based on the job function and material-specific requirements related to the handling of hazardous materials (i.e., operation of emergency valves, cargo tank specification requirements, security awareness, etc.). It remains the responsibility of a hazmat employer to determine the extent to which the CDL hazmat endorsement satisfies the training requirements of the HMR.

  8. Do the HMR training regulations apply to foreign flag vessels carrying hazardous materials?

    A. Yes, the regulations apply to each domestic and foreign vessel when in navigable waters of the United States.

  9. Do the HMR training regulations apply to a hazmat employer and employees who operate a bulk vessel transporting hazardous materials?

    A. No. Except for transportation in bulk packagings (See § 171.8), the bulk carriage of hazardous materials by water is governed by 46 CFR Chapter I. See § 176.5(d).

Last Updated: Mar 27, 2008
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