DOT Training Requirements

I have written several articles and Traffic Bulletins on training and there is good reason. It consistently ranks as the number one inquiry from members and continues to be one of the most cited issues by DOT inspectors who visit our members. I want to touch on the high points of the main training topics required by the DOT: hazmat, driver and drug & alcohol training.

Hazmat Training (172.704)
A hazmat employer must train, test and certify every hazmat employee who has any function that directly affects hazardous materials transportation safety.

Function-Specific Training Requirements (172.704)
Each hazmat employee shall be provided function-specific training concerning requirements that are applicable to the functions the employee performs. Examples of such training include cylinder filling, cylinder requalification and driver.

Security Awareness (172.704)
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.

Security, In-Depth Training (172.704)
In-depth security training must include security objectives, specific procedures, employee responsibilities, actions in the event of a security breach and organizational security structure.

Driver Training (177.816)
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.

GAWDA has a Driver Training Manual available that is an excellent source for driver safety meetings. It is set up as six short training modules, with each module having its own test. A final overall test covers all the topics in the manual.

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/address of the person providing the training
• Certification that the hazmat employee has been trained and tested.

Reasonable Suspicion Training for Driver Supervisors (382.603)
This training is for driver supervisors. Each employer shall ensure that all persons designated to supervise drivers receive training on alcohol misuse and controlled substances use. The training will be used by the supervisors to determine whether reasonable suspicion exists to require a driver to undergo testing under 382.307 (reasonable suspicion testing). The training shall include the physical, behavioral, speech and performance indicators of probable alcohol misuse and use of controlled substances.

Training Frequency
The hazmat (general awareness, security awareness, safety and function specific—which includes driver training) 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. I also encourage you to stay focused on hazmat, DOT, cylinder filling, cylinder requalification, and CDL.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT, Security, OSHA & EPA 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.