Who needs 49 CFR training?

49 CFR training refers to training on the U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR), which are primarily found in Title 49 of the Code of Federal Regulations (49 CFR), specifically in Parts 171-180. These regulations govern the safe transportation of hazardous materials in commerce within the United States, whether by highway, rail, air, or vessel.

Who Needs 49 CFR Training?

Essentially, anyone who performs a “hazmat function” in the transportation or pre-transportation of hazardous materials needs 49 CFR training. This is a broad definition and covers a wide range of individuals and job roles within a company.

The DOT defines a “hazmat employee” as a person who, in the course of employment, directly affects hazardous materials transportation safety. This includes, but is not limited to:

• Loading, unloading, or handling hazardous materials: This includes warehouse workers, dock workers, and forklift operators.
• Preparing hazardous materials for transportation: This involves:
  • Classifying hazardous materials (determining their hazard class, proper shipping name, and UN number).
  • Selecting appropriate packaging (including bulk packaging, drums, and containers).
  • Filling and closing packages or containers.
  • Marking and labeling packages with the correct hazardous material information.
  • Placarding transport vehicles and freight containers.
  • Preparing shipping papers (e.g., manifest, bill of lading) accurately.
  • Providing emergency response information.
• Manufacturing, testing, reconditioning, repairing, modifying, marking, or otherwise representing containers or packages as qualified for use in the transportation of hazardous materials.
• Operating a vehicle used in the transportation of hazardous materials (e.g., truck drivers, train operators, pilots, ship crew members).
• Being responsible for the safety of transporting hazardous materials. This includes supervisors, managers, and anyone involved in logistics and compliance.
• Receiving and forwarding packages containing hazardous materials.
• Responding to damaged containers, spills, or leaks and reporting incidents.

Key Aspects of 49 CFR Training:

The regulations (specifically 49 CFR 172.704) mandate that hazmat training include the following components:

1. General Awareness/Familiarization Training: Provides an overview of the HMR, helping employees recognize and identify hazardous materials and understand the basic principles of hazardous materials transportation.
2. Function-Specific Training: This is crucial and tailored to the specific tasks an employee performs. For example, a person who prepares shipping papers will need different function-specific training than a person who loads and unloads hazmat.
3. Safety Training: Covers the hazards associated with the materials being handled, measures to protect employees from exposure, emergency response procedures, and accident avoidance.
4. Security Awareness Training: Addresses the security risks related to hazardous materials transportation and how to recognize and respond to potential security threats.
5. In-Depth Security Training (if applicable): Required for employees involved with higher-risk hazardous materials (those requiring a security plan). This training covers specific company security objectives, procedures, and responsibilities.

Training Frequency:

• Initial Training: New hazmat employees or those whose job functions change must complete their training within 90 days of employment or job change. They can perform hazmat functions before completing training only if under the direct supervision of a properly trained and knowledgeable hazmat employee.
• Recurrent Training: All hazmat employees must receive refresher training at least once every three years. This ensures their knowledge remains current with any regulatory changes.
• Update Training: If there are significant changes to the HMR that affect an employee’s job function, they must receive updated training sooner than the three-year cycle.

Consequences of Non-Compliance:

Failure to comply with 49 CFR training requirements can result in significant civil penalties (fines) from the DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA). In serious cases, criminal penalties may also apply.

In summary, if your company ships, offers for transport, or handles hazardous materials in any capacity within the United States, a thorough understanding of and compliance with 49 CFR is essential, and appropriate training for all “hazmat employees” is a non-negotiable requirement. Sign up for your 49 CFR DOT Hazmat Training today!

Kirstie Chisholm

Manages Hazmat School’s E-Learning courses and blog. Kirstie has extensive experience in the online training and education industry. Kirstie has worked with courses that offer a variety of safety and environmental certifications that satisfy OSHA, EPA and DOT requirements.