DOT Training Requirements

Training consistently ranks as the number one inquiry that I get from the membership. Here are the high points of the main training topics required by the DOT: hazmat, driver, and drug and alcohol training.

Hazmat Training (172.700-.704)
The hazmat employer must train its hazmat employees to recognize and identify hazardous materials as well as safely load, unload, handle, store and transport hazardous materials. A hazmat employer must train, test and certify every hazmat employee who has any function that directly affects hazardous materials transportation safety.

General Awareness — Each hazmat employee shall be provided general awareness/familiarization training designed to enable the employee to recognize and identify hazardous materials.

Safety — Each hazmat employee shall receive safety training concerning emergency response information and measures to protect the employee from the hazards associated with hazardous materials.

Function-Specific — Each hazmat employee shall be provided function-specific training concerning requirements that are specifically applicable to the functions the employee performs. Some examples of function-specific training for our GAWDA members would be:

  • Cylinder filling
  • Cylinder requalification
  • Driver (see the driver training section).

Security Awareness — This training must include an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. A component covering how to recognize and respond to possible security threats must be included. This must be done when doing the hazmat training.

Security, In-Depth Training — In-depth security training must include company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and organizational security structure.

Training must be done once, and then whenever you update your security plan.

Driver Training (177.816)
177.816 says that the driver must receive training on the safe operation of the motor vehicle that will be transporting hazardous materials. Please note: 177.816(c) states: “The driver training requirements may be satisfied by compliance with the current requirements for a Commercial Driver’s License (CDL) with a tank vehicle or hazardous materials endorsement.”

Hazmat Record of Training (172.704(d))
A record of current training, inclusive of the preceding three years, must be created and retained by each hazmat employer for each hazmat employee, for as long as that employee is employed by the employer as a hazmat employee, and for 90 days thereafter.

The record must include:

  • Hazmat employee’s name
  • Most recent training completion date of the hazmat employee’s training
  • Description, copy or the location of the training materials used to meet the training requirements
  • Name and address of the person providing the training
  • Certification that the hazmat employee has been trained and tested.

Drug and Alcohol
382.603 covers training for driver supervisors. Each employer shall ensure that all persons designated to supervise drivers receive at least 60 minutes of training on alcohol misuse and receive at least an additional 60 minutes of training on controlled substances use in order to determine whether reasonable suspicion exists to require a driver to undergo testing.

Training Frequency
The hazmat (general awareness, safety, function-specific—which includes driver training—and security awareness) must be done at least every three years.

The supervisor drug and alcohol awareness training is only a one-time training, but I highly recommend reviewing this with the driver supervisors every two or three years.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT & Homeland Security Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at (573) 785-5111 and at mldsafety@hotmail.com.