Who is a hazmat employee
The Hazardous Materials Regulations (HMR), 49 CFR Parts 171 to 180, are enforced by DOT. PHMSA writes the rules. A hazmat employer is anyone who uses employees to transport hazmat, cause it to be shipped, or make, test or repair packagings for it. This includes government agencies and self-employed people such as owner-operators.
A hazmat employee is anyone, employed or self-employed, whose work directly affects hazmat transportation safety. Examples:
- People who load, unload or handle hazardous materials.
- People who prepare hazmat for shipment: classify it, pack it, mark and label it, or fill out shipping papers.
- People responsible for the safety of hazmat in transport.
- Drivers of vehicles carrying hazmat.
- People who make, test, repair or recondition packagings for hazmat.
The training rule: 49 CFR 172.704
| Part of training | What it covers |
|---|---|
| General awareness and familiarization | The HMR as a whole, so you can recognize and identify hazardous materials |
| Function-specific | The rules for the tasks you actually do |
| Safety | Emergency response information, protection from hazards, avoiding accidents |
| Security awareness | Security risks in hazmat transport and how to recognize and respond to threats |
| In-depth security | Only for employers that must have a security plan (Subpart I) |
| Driver training (49 CFR 177.816) | For employees who operate a motor vehicle |
Timing
- New employees, and employees who change job functions, must finish training within 90 days.
- Until then, they may do hazmat tasks only under the direct supervision of a properly trained employee.
- Recurrent training is required at least once every 3 years, counted from the last training date.
- Training from a previous employer can count if a current training record is obtained.
- OSHA or EPA training counts only for the parts that match the DOT topics.
Testing, certification and records
- Your employer must test you by appropriate means: written, verbal, performance-based, or a mix. This applies even when an outside company trains you.
- There is no federal exam or card, and DOT does not pre-approve most trainers.
- The employer certifies that you were trained and tested, and may designate an outside source to do this for it.
- Records cover the preceding 3 years and are kept for 90 days after you leave.
- Each record has your name, your latest training date, a description or copy of the materials, the trainer's name and address, and the certification.
The nine hazard classes
| Class | Name | Divisions |
|---|---|---|
| 1 | Explosives | 1.1 mass explosion; 1.2 projection; 1.3 mainly fire; 1.4 no significant blast; 1.5 very insensitive (blasting agents); 1.6 extremely insensitive |
| 2 | Gases | 2.1 flammable gas; 2.2 non-flammable compressed gas; 2.3 poisonous gas |
| 3 | Flammable and combustible liquid | None |
| 4 | Flammable solids and similar | 4.1 flammable solid; 4.2 spontaneously combustible; 4.3 dangerous when wet |
| 5 | Oxidizers and organic peroxides | 5.1 oxidizer; 5.2 organic peroxide |
| 6 | Poisonous and infectious | 6.1 poisonous material; 6.2 infectious substance |
| 7 | Radioactive material | None |
| 8 | Corrosive material | None |
| 9 | Miscellaneous hazardous material | None |
The Hazardous Materials Table
The Hazardous Materials Table in 49 CFR 172.101 is the starting point for most hazmat tasks. Each entry gives the information you copy onto packages and shipping papers. Section 172.202 points to these columns:
| Column | What it gives you | Where you use it |
|---|---|---|
| Column 2 | Proper shipping name | Shipping paper and package marking |
| Column 3 | Hazard class or division | Shipping paper, labels and placards |
| Column 4 | Identification number (UN, NA or ID number) | Shipping paper, package marking and some placards |
| Column 5 | Packing group (I, II or III) | Shipping paper |
Use the proper shipping name exactly as the table shows it. A material that is not hazardous must not be described with a hazard class or identification number, with a few international exceptions.
Shipping papers
The shipping paper tells carriers and emergency responders what is in the load. The basic description must show four items in this order, with nothing in between:
- Identification number (for example UN1203)
- Proper shipping name (for example Gasoline)
- Hazard class or division (for example 3), with any subsidiary hazard in parentheses
- Packing group in Roman numerals (for example PG II), where one applies
The entry also shows the total quantity with a unit of measure and the number and type of packages, such as 12 drums.
Emergency response telephone number
- Must be on the shipping paper.
- Must be monitored at all times while the material is in transport, including storage along the way.
- Must reach a knowledgeable person, or someone with immediate access to one. Answering machines, answering services and callback pagers do not count.
Shipping papers in the truck
- Keep the hazmat paper tabbed or on top of other papers.
- At the wheel: within reach with your seat belt on, and visible or in the driver's door pouch.
- Away from the wheel: in the driver's door pouch or on the driver's seat.
Marking packages
Markings are the words and numbers on a package. A non-bulk package must be marked with:
- The proper shipping name and identification number from the Hazardous Materials Table, with UN, NA or ID in front of the number.
- ID number characters at least 12 mm (0.47 inches) high, except on small packages.
- The technical name in parentheses, for certain generic shipping names.
- The name and address of the consignor or consignee, with some exceptions.
Labelling packages
Hazard labels are diamond-shaped symbols on packages that show the hazard class.
- Place labels on a side other than the bottom, on the same surface as the proper shipping name marking when possible.
- Put primary and subsidiary labels next to each other, within 150 mm (6 inches).
- Each label needs a contrasting background or a dotted or solid border.
- Labels must be clearly visible and not covered by tape, markings or attachments.
- Packages of 64 cubic feet or more need labels on at least two sides or ends.
Placarding vehicles
Placards are large diamond signs on vehicles, freight containers, bulk packagings and rail cars. Show them on each side and each end.
| Table | Examples | When a placard is needed |
|---|---|---|
| Table 1 | Explosives 1.1 to 1.3; 2.3 poisonous gas; 4.3 dangerous when wet; 6.1 poisonous by inhalation; certain 5.2 organic peroxides; Radioactive Yellow III | Any quantity |
| Table 2 | Divisions 1.4 to 1.6, 2.1 and 2.2; Classes 3, 8 and 9; 4.1, 4.2, 5.1, other 5.2 and other 6.1; combustible liquids | Not needed for non-bulk highway or rail loads under 1,001 pounds aggregate gross weight |
- The 1,001-pound exception never applies to bulk packagings.
- A load of two or more Table 2 categories in non-bulk packages may use one DANGEROUS placard, unless 2,205 pounds or more of one category was loaded at one facility.
- Placards must be visible from the direction they face, at least 3 inches from other markings, with words reading left to right.
- The carrier keeps placards clean and readable.
Safety and security awareness
Safety training
Every hazmat employee gets safety training. It covers emergency response information for the materials you handle, how to protect yourself from workplace hazards such as spills, fires or exposure, and how to avoid accidents, for example by securing packages so they cannot move or leak.
- Know where the shipping papers and the emergency response telephone number are.
- Follow your employer's procedures for leaks, spills and damaged packages.
- Use the protective equipment your employer gives you for the materials you handle.
Security awareness
Every hazmat employee also gets security awareness training: the security risks of moving hazardous materials and how to recognize and respond to possible threats. Examples include people asking unusual questions about loads, unattended vehicles, or packages that look tampered with. Report concerns using your employer's procedures.
Some employers must have a written security plan under Subpart I of Part 172. Their hazmat employees also need in-depth security training on that plan and their role in it.
Emergencies and the ERG
PHMSA's Emergency Response Guidebook (ERG) helps first responders during the initial phase of a hazmat transport incident. The current edition is the 2024 ERG, also available as a mobile app.
| ERG section | Use it to |
|---|---|
| Yellow pages | Find a material by its UN number |
| Blue pages | Find a material by its name |
| Orange pages | Read the guide: hazards, safety and response steps |
| Green pages | Find initial isolation and protective action distances |
| White pages | Reference: shipping paper guide, placard charts, glossary and more |
- Identify the material from placards, labels or shipping papers.
- Find its UN number or proper shipping name.
- Look it up in the yellow or blue pages.
- Turn to the orange guide page.
- Use the green pages to find initial isolation and protective action distances when they apply.
Key terms
The 16 words and rules to know for this test. Read the list or study them as flashcards: flip each card, then mark it "Know it" or "Still learning".
- Hazardous Materials Regulations
- The HMR, 49 CFR Parts 171 to 180, enforced by DOT. PHMSA writes the rules.
- Hazmat employee
- Anyone, employed or self-employed, whose work directly affects hazmat transportation safety, such as loaders, packers and drivers.
- 49 CFR 172.704
- The training rule covering general awareness, function-specific, safety and security awareness training, plus in-depth security where required.
- Function-specific training
- Training on the rules for the tasks you actually do, given by your employer in addition to general awareness.
- 90-day training deadline
- New employees, and those who change job functions, must finish training within 90 days. Until then, they work under direct supervision.
- Recurrent training
- Required at least once every 3 years, counted from the last training date.
- Employer certification
- The employer certifies you were trained and tested. There is no federal exam or card, and records are kept for 90 days after you leave.
- Hazard class and division
- The first number is the class and the number after the dot is the division. Division 2.3 means poisonous gas.
- Hazardous Materials Table
- The table in 49 CFR 172.101 giving the proper shipping name, hazard class, identification number and packing group for each entry.
- Basic description order
- On the shipping paper: identification number, proper shipping name, hazard class or division, then packing group, with nothing in between.
- Emergency response telephone number
- Must be on the shipping paper and monitored at all times in transport by a knowledgeable person. Answering machines do not count.
- Shipping papers in the cab
- At the wheel, keep them within reach with your seat belt on. Away from the wheel, put them in the door pouch or on the driver's seat.
- Labels
- Diamond-shaped symbols on packages showing the hazard class. Primary and subsidiary labels go next to each other, within 150 mm (6 inches).
- Placard Table 1
- Materials such as Explosives 1.1 to 1.3, 2.3 poisonous gas and 4.3 dangerous when wet, which need placards in any quantity.
- 1,001-pound exception
- Table 2 materials in non-bulk highway or rail loads under 1,001 pounds aggregate gross weight need no placards. It never applies to bulk.
- Emergency Response Guidebook (ERG)
- PHMSA's book for first responders. Yellow pages list UN numbers, blue list names, orange give guides and green give isolation distances.