Frequently Asked Questions Regarding
Training Requirements

May a hazmat employer/employee train and test themselves?
Self-training is acceptable as long as all of the training requirements in 172.704 are met.

Must an instructor and the training program itself be DOT certified?
Except for certain FAA required training under 14CFR, the DOT does not certify training programs or instructors.  The hazmat employer must determine an instructors qualifications based on their need.

Must the hazmat employee "pass" a test?
The regulations do not state that the hazmat employee must "pass" a test.  However, an employee may only be certified in areas in which he/she can successfully perform their hazmat duties.  Paragraph 172.704(d) states, among other things, that a hazmat employees record of training must include certification that the employee has been trained and tested, as required by this subpart.

What type of test is required?
Training and testing may be accomplished in a variety of ways: performance, written, oral or a combination of these.  Any test that ensures that the hazmat employee can performm the assigned duties in accordance with the regulations is acceptable. 

Does the instructor who conducts the training and tests the hazmat employee, certify that the hazmat employee is trained?
No, only the hazmat employer may certify that an employee is trained. 

Do the training requirements apply to employers/employees that only ship consumer commodities?
Yes.  

If a violation of the regulations occurs, what type of fines could be involved?
Violations of any hazardous materials regulations, including training, could result in civil penalties of up to $50,000 per day for each violation and, when appropriate, criminal penalties of up to $500,000 and/or imprisonment of up to 5 years.