Who Needs Hazardous Materials (HazMat) Training?
You need HazMat training for work, but a quick search online just gives you an alphabet soup of acronyms and confusing terms.
Many different regulations apply to hazardous materials in the U.S. Some laws protect workers, some the environment, and some the general public. You might need to learn only one type, or you might need all three.
It all depends on where you work and what you do. Let's break it down.
What Are Hazardous Materials?
In the broadest definition, a hazardous material (often shortened to HazMat) includes any substance that's toxic, corrosive, flammable, or explosive.
Regulations that deal with hazardous materials (or hazardous waste) often have narrower definitions based on what the regulations are for.
The EPA, for example, only regulates specific kinds of solid hazardous waste, and they developed a series of questions that define hazardous waste for their purposes.
What Are "Dangerous Goods"?
To streamline international trade and communication, some HazMat regulations in the U.S. incorporate relevant international standards.
The United Nations uses the language "dangerous goods" instead of hazardous materials when they talk about international shipping, so our regulations for air and sea transportation use these terms, too. For the most part, they're the same thing.
Who Regulates Hazardous Materials and Hazardous Waste in the U.S.?
Due to the dangerous nature of hazardous materials and waste, many different regulatory bodies exist. The regulations you're subject to will vary by jurisdiction, material type, industry, job duties, and more.
Relevant regulations in the U.S. may include the:
- Occupational Safety and Health Administration (OSHA), which regulates the safety of employees dealing with hazardous materials and hazardous waste
- Environmental Protection Agency (EPA), which regulates effective hazardous waste management
- State-level OSH and/or environmental agencies, which may have slightly different requirements
- Department of Transportation (DOT), which regulates the safe transportation of hazardous materials
- International Air Transport Association (IATA), for safe international air transportation
- International Maritime Organization (IMO), for safe international maritime transportation
Who Needs HazMat Training?
That's a simple question with a complicated answer. If your job involves generating, handling, storing, transporting, treating, or disposing of hazardous materials or hazardous waste, you definitely need some kind of HazMat training.
What kind you need (and how much) depends on your industry, jurisdiction, job duties, and the type of hazardous substance you work with. Let's tackle this question by looking at the training requirements of each regulatory body we mentioned above.
OSHA Hazardous Materials Training Requirements
OSHA is responsible for most regulations that protect the health and safety of employees that interact with hazardous materials and hazardous waste.
They do this by setting exposure limits, requiring measures that reduce exposure, and ensuring that workers understand the danger of hazardous materials they work with (and how to protect themselves).
There are several kinds of hazardous materials training you might need under OSHA, depending on your industry and job duties.
What is GHS/HazCom Training and Who Needs It?
OSHA has requirements for chemical labeling and classification called the Hazardous Communication Standard (HCS or HazCom for short). There's a similar international standard called the Globally Harmonized System (GHS).
OSHA requires all employers to provide GHS/HazCom training to workers who have potential exposure to hazardous chemicals in the workplace. The training covers how to read HazMat labels and how to look up important information on the Safety Data Sheet (SDS).
What Hazardous Substances and Materials Require OSHA Training?
In addition to HazCom, OSHA requires employers to train employees about dangers and precautions related to any hazardous substance they may be exposed to at work.
OSHA requires this training for anyone who may be exposed to silica, asbestos, MDA, and/or lead. The training you need depends on your exposure risk.
For some workers, training that explains all hazardous materials together at a high level is fine. Other workers may need focused training on the hazards of a specific substance.
Also, be aware that OSHA standards vary by industry. For example, workers in the construction industry may need different training than manufacturing workers.
What is Bloodborne Pathogen Training and Who Needs It?
Although blood and other bodily fluids don't quite fit under the traditional HazMat definition, they still qualify because they can put workers at risk for infection.
Any employee with occupational exposure to bodily fluids (from tattoo artists to hospital staff)s has to receive Bloodborne Pathogen training. BBP training teaches you how to handle bodily fluids safely. It needs to be repeated at least once a year.
What is HAZWOPER Training and Who Needs It?
HAZWOPER training is designed specifically for workers who clean up, treat, store, and dispose of hazardous waste.
This includes emergency responders, operators at uncontrolled hazardous waste sites (like Superfund cleanups), and personnel who handle waste at TSD (Treatment, Storage, and Disposal) facilities. OSHA only requires HAZWOPER for those three categories of workers and their supervisors.
There are three types of HAZWOPER training: two levels of initial HAZWOPER training, plus an 8-hour annual refresher course. Workers have to choose either a 24-hour or 40-hour initial training based on the extent of potential exposure.
Other workers who may encounter hazardous waste, like hospital employees, don't necessarily need HAZWOPER. They can receive training specific to their exposure risk, instead.
EPA Hazardous Material / Hazardous Waste Training Requirements
The EPA is responsible for regulations on the generation, storage, treatment, and disposal of hazardous waste.
What is RCRA Training and Who Needs It?
The Resource Conservation and Recovery Act (RCRA) regulates hazardous waste "from cradle to grave."
The EPA requires Large Quantity Generators (LQGs) of hazardous waste to train their employees on relevant RCRA provisions within six months. They also have to provide annual refresher training. LQG workers need RCRA training if they work with hazardous waste, signing manifests, managing storage and/or inventory, conducting inspections, or responding to emergencies.
Small Quantity Generators (SQGs) have training requirements as well, but they're more relaxed.
What is UST Training and Who Needs It?
The RCRA also regulates underground storage tanks (USTs) that have potentially hazardous substances, typically petroleum or oil.
UST operators have to train employees in how these tanks work and how to respond to an emergency. UST training requirements vary by state and are divided into three classes based on a worker's degree of responsibility.
Does the EPA Require Other Hazardous Materials/Waste Training?
Professionals in charge of environmental compliance may need training on other hazardous waste legislation, including CERLA and EPCRA.
DOT (& Friends) Hazardous Materials Training Requirements
The DOT is responsible for regulating the safe transportation of hazardous materials.
What is DOT 49 CFR Training?
Title 49 of the Code of Federal Regulations (49 CFR, for short) contains all of the federal laws related to transportation. These laws are mostly administered and enforced by the DOT and its agencies, though some parts are administered by the Department of Homeland Security (DHS).
Some of the regulations in 49 CFR require training for relevant employees, so these are collectively referred to as 49 CFR training. Examples include DOT HazMat training and DOT supervisor training for employee drug and alcohol testing.
What are the DOT HazMat Training Requirements?
Relevant employees have to be trained in a few different areas, according to 49 CFR 172:
- General Awareness: covers the Hazardous Materials Regulations (HMR), as well as the hazard communication standards for recognizing and identifying hazardous materials
- Function-Specific: covers the regulations specific to your job functions (like packaging or marking/labeling)
- Safety: covers emergency response information, procedures for avoiding accidents, and the measures your employer has taken to protect you from exposure
- Security Awareness: covers the security risks associated with HazMat transport, how to enhance security, and how to recognize and respond to possible security threats
- In-Depth Security: covers your specific employer's security plan
- Modal-Specific: covers the additional regulations that apply to the relevant mode(s) of transportation (rail, aircraft, vessel, or public highway)
Who Needs DOT HazMat Training?
Each "HazMat Employer" must train each "HazMat Employee" in the relevant areas of the HMR.
A "HazMat employer" is a person or entity who uses one or more of its employees in connection with:
- transporting hazardous materials in commerce
- causing hazardous materials to be shipped in commerce
- repairing or modifying containers, drums, or packages to use in the transportation of hazardous materials
If you work for a HazMat employer, you need training if your job duties directly affect the safety of HazMat transportation. Example activities include:
- loading, unloading, or handling hazardous materials
- preparing hazardous materials for transportation
- operating a vehicle to transport hazardous materials
- exercising responsibility for the safety of hazardous material transportation
- manufacturing, testing, reconditioning, repairing, modifying, marking, or otherwise representing containers, drums, or packagings as qualified for use in the transportation of hazardous materials
Is DOT HazMat Training Mandatory Even If I Ship Small Amounts?
DOT HazMat training is mandatory for everyone. There are no exceptions based on frequency or quantity.
All HazMat employees need training, but the scope of training can be narrow if your duties are narrow. For example, if you only ship a few specific hazardous materials, you only need to learn what is relevant for those materials.
How Soon Does an Employee Need DOT Hazardous Materials Training?
Employees need to complete initial DOT HazMat training within 90 days of being hired or taking on HazMat duties. Until they're trained, they need to perform any HazMat duties under the direct supervision of a properly trained HazMat employee.
What is the Required Frequency of DOT Hazardous Materials Training?
DOT HazMat training needs to be repeated at least once every 3 years. If security plans or job functions change, updated training needs to be done within 90 days.
What is IATA Dangerous Goods Training? Who Needs It?
The IATA's Dangerous Goods Regulations (DGR) set the rules for air transportation, so the required training falls under the "modal-specific" type of training required by DOT.
If you are a HazMat employee who affects the safe transportation of hazardous materials by air, you need IATA Dangerous Goods training. While most DOT HazMat training is required every 3 years, IATA requires a refresher on its regulations every 2 years.
What is IMDG Dangerous Goods Training? Who Needs It?
International Maritime Dangerous Goods (IMDG) training is modal-specific training for dangerous goods that are shipped by vessel. These rules are set by the International Maritime Organization (IMO).
If you are a HazMat employee who affects the safe maritime transportation of hazardous materials, you need IMDG training.
The IMDG's training frequency is every 3 years, like most DOT HazMat training.
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