The document outlines a webinar that discusses the training requirements under DOT and IATA regulations for hazardous materials employees. It emphasizes the necessity of training every three years, detailing the required elements including general awareness, function-specific training, safety, and security awareness. Additionally, it highlights the potential consequences for non-compliance, such as civil penalties and impacts on public safety.

1. Training:
Who needs it?
And how much?
DOT Hazardous Materials and IATA

2. Meet Your Moderator:
Sasha Laferte

3. 1. All lines are muted, use the chat panel for tech issues.
2. Ask questions using the questions panel
3. Unanswered questions will be answered via email after
the webinar
4. Webinar recording and slides will be emailed to you
tomorrow morning.
A Few Logistical Items

4. Meet Your Presenter
Doug Graham, CHMM
Sr. EH&S Consultant &
External Training Manager
dgraham@triumvirate.com
22 Years training hazardous
materials shippers

5. OBJECTIVE
Learn who needs DOT
Hazardous Materials and IATA
training and how much.

6. Transporting Hazardous
Materials: DOT & IATA
Who needs it?
How much do they need?
Potential consequences
of falling short

7. DOT Training
U.S. Department of Transportation Hazardous Materials
Regulations (49 CFR 100-185) Training

8. Basic Overview
Required every 3 years
5 training elements
Applicable to “hazmat employees”
Non-prescriptive

9. Training Requirements
49 CFR 172.704
Required Elements:
172.704(a)(1): General Awareness
172.704(a)(2): Function-Specific
172.704(a)(3): Safety
172.704(a)(4): Security Awareness
172.704(a)(5): In-Depth Security
Applicable to “hazmat employees” as defined in 49 CFR
171.8 (those who affect hazmat transportation safety)

10. Applicable to “hazmat employees” as defined in 49 CFR
171.8 (those who affect hazmat transportation safety)
Training Requirements
49 CFR 172.704
Required Elements:
172.704(a)(1): General Awareness
172.704(a)(2): Function-Specific
172.704(a)(3): Safety
172.704(a)(4): Security Awareness
172.704(a)(5): In-Depth Security
Consists of an overview of those regulatory topics
which do not directly affect the employee’s hazmat-
related tasks. The training can be shorter and in less
detail, but cannot be skipped.
172.704(a)(1): General Awareness

11. Applicable to “hazmat employees” as defined in 49 CFR
171.8 (those who affect hazmat transportation safety)
Training Requirements
49 CFR 172.704
Required Elements:
172.704(a)(1): General Awareness
172.704(a)(2): Function-Specific
172.704(a)(3): Safety
172.704(a)(4): Security Awareness
172.704(a)(5): In-Depth Security
172.704(a)(2): Function-Specific
Training in regulatory topics that directly affect the
employee’s job functions- must be in sufficient
detail and length to cover the topic thoroughly.

12. Applicable to “hazmat employees” as defined in 49 CFR
171.8 (those who affect hazmat transportation safety)
Training Requirements
49 CFR 172.704
Required Elements:
172.704(a)(1): General Awareness
172.704(a)(2): Function-Specific
172.704(a)(3): Safety
172.704(a)(4): Security Awareness
172.704(a)(5): In-Depth Security
172.704(a)(3): Safety
DOT does not mandate any additional training under
this paragraph, but does require that hazmat
employees be trained in related safety requirements,
mentioning specifically OSHA’s Hazard
Communication and HAZWOPER standards.

13. Applicable to “hazmat employees” as defined in 49 CFR
171.8 (those who affect hazmat transportation safety)
Training Requirements
49 CFR 172.704
Required Elements:
172.704(a)(1): General Awareness
172.704(a)(2): Function-Specific
172.704(a)(3): Safety
172.704(a)(4): Security Awareness
172.704(a)(5): In-Depth Security
172.704(a)(4): Security Awareness
All hazmat employees must receive an overview of
the role that hazardous materials have played, and
may continue to play, in terrorist activities and to
safeguard against illicit use of such materials and
address potential security risks

14. Applicable to “hazmat employees” as defined in 49 CFR
171.8 (those who affect hazmat transportation safety)
Training Requirements
49 CFR 172.704
Required Elements:
172.704(a)(1): General Awareness
172.704(a)(2): Function-Specific
172.704(a)(3): Safety
172.704(a)(4): Security Awareness
172.704(a)(5): In-Depth Security172.704(a)(5): In-Depth Security
In accordance with 49 CFR 172.800-822, certain
shippers and carriers must develop and implement
site-specific written security plans. Those employees
who have roles and responsibilities under the plan
must receive training in the specifics of the plan.

15. Training Requirements
49 CFR 172.704
• Training is required every 36 months
for all hazmat employees.
• Records must be maintained for the
duration of employed, plus an
additional 90 days.
• New employees must be trained within
90 days.
• Records must include certification that
the employee was trained and tested.

16. Who are the Hazmat Employees?
• Only hazardous waste manifest signers
and shipping departments really need
DOT Hazardous Materials training
Common Misconception
• There are many types of employees
involved who perform pre-transport
functions related to hazmat shipments.
A common problem amongst
employers is having unidentified,
untrained hazmat employees acting
independently.
Reality (all “hazmat
employees”)

17. Hazmat Employees
(other than hazardous waste manifest signers)
Shipping/Receiving
• Hazardous products, articles and chemicals (sending/receiving
and potentially returning)
IT • Lithium batteries
Lab Personnel
• Potentially infectious biological materials, dry ice,
formaldehyde
Researchers • Genetically modified microorganisms, new compounds
Healthcare • Patient specimens
EVS/Housekeeping • Regulated medical waste
Other
• Purchase or reuse UN-spec packagings
• Self-transport

18. How Much Do They Need?
• Length and curriculum of training not
specified.
• How many hours devoted to DOT
training is up to the employer and
should depend on the employees’
specific job function.

19. How Much Do They Need?
Depending upon job function, some
employees may require supplemental
“function-specific” training beyond a basic
course, including those involved in:
• Shipping radioactives
• Shipping by air (IATA)
• Using special permits
• Having an active role in a security
plan

20. How Much Do They Need?
Although not specifically required following a comprehensive
basic training, some employees may find that specific
supplemental training in a particular topic to be helpful,
for example:
• Shipping lithium batteries
• Shipping infectious
substances

21. Potential Consequences
of Falling Short
Incidents affecting public
safety and/or the
environment
Rejected shipments
Civil penalties up to
$75,000 per violation

22. IATA Training
International Air Transport Association Dangerous
Goods Regulations

23. Basic Overview
Purpose was to create uniformity among airlines
and comply with international air regulations (ICAO)
Required every 3 years (not 2)
DOT is a pre-requisite
DOT allows the use of IATA regs and most are
enforceable by DOT (through the FAA)

24. Who Needs It?
• Only those involved in shipping hazardous materials
internationally by air require IATA training
Common Misconception
• All employees involved in preparing and shipping
hazardous materials internationally and
domestically by FedEx Express, commercial
passenger airlines or UPS (international only)
require IATA and DOT training
Reality

25. IT
• Packaging and shipping lithium
batteries
Lab Personnel
• Preparing shipments containing
dry ice
Researchers
• Offering shipments of articles and
devices, and new compounds
Employees commonly overlooked:
Who Needs It?

26. How Much Do They Need?
• IATA training is considered a function-specific element
of DOT training and is therefore also required every 3
years
• Like the DOT regulations, hazmat employees need
training in the level of detail commensurate with the
tasks they perform
See USDOT letter of interpretation #09-0240,
dated July 2, 2010.

27. Applicable to “hazmat employees” as defined in 49 CFR
171.8 (those who affect hazmat transportation safety)
Training Requirements
49 CFR 172.704
Required Elements:
172.704(a)(1): General Awareness
172.704(a)(2): Function-Specific
172.704(a)(3): Safety
172.704(a)(4): Security Awareness
172.704(a)(5): In-Depth Security
172.704(a)(2): Function-Specific
IATA training falls under the function-specific DOT
training paragraph.
IATA Training Sec. 1.5 is not enforceable unless the
provision is also required under 49 CFR 172.700-704

28. How Much Do They Need?
Depending on job function, some employees may
require supplemental training, including:
• Shipping radioactives
• Shipping lithium
batteries
• Shipping infectious
substances

29. Potential Consequences of
Falling Short
• Incidents affecting public safety and/or the environment
• Rejected shipments (very common)
• Civil penalties up to $75,000 per violation (issued by the
Federal Aviation Administration (FAA))
• Follow-up FAA inspections
Additionally, it is very common for FAA to perform
routine and random inspections of shippers who
complete Dangerous Goods Declaration forms.

30. Conclusion
It’s up to the employer to make
sure all hazmat employees
are trained appropriately.

31. Other Training Requirements
Other training requirements typical for EH&S professionals include:
• Emergency Response (HAZWOPER)
• Hazardous Waste Management (RCRA)
15 Separate OSHA Standards, including
• Hazardous Chemicals in Laboratories
• Control of Hazardous Energy (Lockout-Tagout)
• Confined Spaces
• Bloodborne Pathogens
• Electrical Safety
• Hazard Communication
• Access to Exposure and Medical Records
• Cranes
• Powered Industrial Trucks
• Portable Fire Extinguishers
• Employee Emergency Plans
• First Aid

32. QUESTIONS?

33. Thank You For Attending!
• You will receive an email
tomorrow with a copy of
this presentation
• Please complete our
short survey
• Expect a transcribed copy
of the Q&A as well as a
special offer.