Hazmat Transportation FAQs

Any employee that meets the definition of a hazmat employee as defined in §171.8 of the Hazardous Materials Regulations must be trained on hazmat. Before any hazmat employee performs any function subject to the Hazmat Regulations they must be trained, tested, and certified by the hazmat employer.

A hazmat employee is an individual that is employed on a full time, part time, or temporary basis by a hazmat employer or who is self-employed, and during the course of employment performs any function subject to the Hazardous Materials Regulations. This includes anyone who:

• Loads, unloads, or handles hazardous materials;
• Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazmat in commerce;
• Prepares hazardous materials for transportation;
• Is responsible for the safety of transporting hazardous materials; or
• Operates a vehicle used to transport hazardous materials.

The hazmat employee must be trained on all the Hazardous Materials Regulations that apply to the function(s) that will be performed. The training must include General awareness/familiarization training, Function-specific training, Safety training, Security awareness training, in-depth security training, and modal specific training, as appropriate.

Before any hazmat employee performs any function subject to the Hazardous Materials Regulations they must be trained. Recurrent training is required once every three years.

However, if a new regulation is adopted or an existing regulation is changed, that relates to a function performed by a hazmat employee, that employee must be trained on the new/revised requirements. This training must be completed before the employee performs the function and before the three year recurrent training is required. The employee only needs to be instructed on the new/revised requirements.

Yes, but only if under the direct supervision of a properly trained and knowledgeable hazmat employee and the new hazmat employee’s training is completed within 90 days of employment or change in job function.

No. There are no requirements in the Hazmat Regulations addressing a trainer’s qualifications.

Yes. When limited quantities or consumer commodities are involved, employees are performing functions subject to the hazmat regulations and must be trained.

Hazardous waste manifests (shipping papers) must be kept for three years after the material is accepted by the initial carrier.

Shippers must keep shipping papers for two years after the material is accepted by the initial carrier.

Carriers must keep shipping papers for one year after the material is accepted.

A copy of the shipping paper or an electronic image must be retained. Each shipping paper copy must include the date of acceptance by the initial carrier. For rail, vessel, or air shipments the date on the shipment waybill, airbill, or bill of lading may be used in place of the date of acceptance by the initial carrier.

A motor carrier that uses a shipping paper without change for multiple shipments of hazardous materials (same shipping name and identification number) may retain a single copy, instead of a copy for each shipment made, IF the carrier also retains a record of each shipment made. This record must include the materials shipping name, identification number, quantity transported, and date of shipment.

In most situations no shipping papers are required. However, if the limited quantity or ORM-D material is a hazardous substance, hazardous waste, marine pollutant, or is offered/intended for air or water transport, a shipping paper would be required.