Re: DOT Training Requirement (HM126F)

["Edwin F. Jackson" <EFJ@asbhr.byu.edu>]

The DOT training requirements originally known as HM126F (the docket 
number for the proposed regulation) was 
published in the Federal Register on May 15 1992 starting with page 
20944.   While the explanations given in the FR are of value, the rule 
itself is found in 49 CFR 172.700-704.  It is not a long or difficult 
rule.  Basically it states that anyone who affects the shipment of a 
hazardous material in commerce must be trained in the duties that 
they will perform, and be familiar with the hazardous materials 
shipping regulations.   I am a little surprised that someone is still 
calling this by HM126F rather than referencing the actual regulation.

The specific language of the regulation states:
172.702(b) A hazmat employee who performs any function subject to the 
requirements of this subchapter may not perform that functin unless 
trained in accordance with the requirements prescribed in this 
subpart.  It is the duty of  each hazmat employer to comply with the 
applicable requirements of this subchapter and to thououghly instruct 
each hazmat employee in relation thereto."

In this case subchapeter means subchapter C of 49 CFR which is the 
subchapter dealing with hazardous material transportation.  A hazmat 
employee is someone who:  Loads unloads or handles hazardous 
materials, tests pacakging, prepares shipping papers, is responsable 
for marking, labeling or packaging HM, transports  or is responsable 
for safety of HM in transportation (see 49CFR 171.8) 

To fulfil this requirement you may:
1. Go to a class offered by numerous comercial training groups
2. Receive training from the Transportation Safety Institute (a Federal 
entity ; this the best DOT HM training I have seen)
3. Prepare your own training

If you prepare your own training you must, maintain a 
copy of the course curriculum, test employees, and record the name of the course 
instructor.

Training must be repeated every two years, and records of training 
must be maintained for each hazmat employee.