Ask X3What does 49 CFR 172.704 (Training requirements) require?
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As Ask X3, your fleet-compliance assistant, here is what 49 CFR 172.704 requires for motor-carrier owners:
### 1. Required Hazmat Training Topics
Every hazmat employee must receive five types of training:
* General Awareness/Familiarization: Training to help employees recognize and identify hazardous materials and become familiar with the rules.
* Function-Specific Training: Training that applies directly to the specific job functions the employee performs (or alternative training on international standards like ICAO or IMDG codes, if applicable).
* Safety Training: Training covering emergency response information, workplace protection measures implemented by the employer, and accident-avoidance methods (like proper package handling).
* Security Awareness Training: Training on transportation security risks, security enhancement methods, and how to recognize and respond to threats. New employees must receive this within 90 days of hire.
* In-Depth Security Training: If your company requires a security plan, employees who handle those hazmat materials, perform regulated functions, or implement the plan must be trained on the plan's objectives, structure, procedures, duties, and responses to security breaches.
### 2. Timelines for Initial and Recurrent Training
* Initial Training: New employees or those changing job functions can perform hazmat duties *before* completing training only if they work under the direct supervision of a properly trained employee, and their training is completed within 90 days of employment or job change. New security awareness training must also be completed within 90 days.
* Recurrent Training: Employees must be retrained at least once every three years. For in-depth security training, recurrent training is required every three years, or within 90 days if your security plan is revised during that three-year cycle.
* Previous Training: You can use relevant training from a previous employer, provided you obtain and keep a current record of that training.
### 3. Recordkeeping Requirements
As the employer, you must create and keep a current training record for each hazmat employee covering the preceding three years.
* Retention Period: Keep the record for as long as the employee works for you, plus 90 days after they leave.
* Availability: You must make these records available upon request to an authorized DOT or enforcement official.
* Required Details: The record must include:
1. The employee's name.
2. The date of their most recent training completion.
3. A description, copy, or location of the training materials used.
4. The name and address of the person who provided the training.
5. A certification that the employee was trained and tested.
As an employer, you are ultimately responsible for compliance under 49 CFR 172.704, regardless of whether the training has been completed.