Explore the sections in this guide
The short answer
Section 172.704 requires a record with the employee’s name, latest completion date, description or location of materials, trainer’s name and address, and certification of training and testing.
Training covers general awareness, function-specific duties, safety, and security awareness; in-depth security training applies when required. Recurrent training is at least every three years. Initial training must be completed within 90 days after employment or a job-function change; regulated functions before completion require direct supervision by a properly trained, knowledgeable employee.
A practical example
A certificate says “hazmat awareness,” but the employee performs loading duties. Match the training to those functions and identify what still needs coverage.
Your next steps
- List regulated job functions.
- Match training and testing to the required components.
- Retain the required record and track the next due date.
Match the person, job function, training, and evidence
| Record or decision | What it addresses | What to check |
|---|---|---|
| Job function | What the employee actually does | Loading, handling, paperwork, and driving can require different content. |
| Training content | The applicable components and function-specific material | A course title is not a full content inventory. |
| Testing | Evidence the required testing occurred | Connect it to the training covered. |
| Training record | Required identifying and certification information | Keep materials and completion details traceable. |
Build the course around the function
A dispatcher preparing transportation information and a driver loading or unloading can both be hazmat employees while needing different function-specific instruction. Ask what duties the person performs, what products and equipment are involved, and which company procedures apply. Generic awareness content can be relevant without satisfying every applicable training component for that person.
Example: an employee changes duties before the next recurrent date
The employee’s recurrent date is not yet due, but the new job includes functions not addressed in the earlier course. Review the changed duties and the applicable initial-training conditions. Do not wait automatically for the old recurrent date. If functions are performed before initial training is complete, confirm the rule’s direct-supervision conditions and completion limit.
Retain the content reference, not only the certificate
The employer’s record needs to identify the description, copy, or location of the materials, along with the other required information. Retain enough detail to determine what was taught. A later revision to a slide deck should not erase the ability to identify the version used for an earlier employee’s training.
Retention and security-plan changes
Keep the record of current training, including the preceding three years, while the person is employed as a hazmat employee and for 90 days afterward. The hazmat employer remains responsible for required training and testing even when an outside instructor provides the course.
When in-depth security training applies, recurrent training is required at least every three years. Employees must also receive training on a revised security plan within 90 days after implementation. A recurrent date on a spreadsheet does not remove that revision deadline.
Map the training to the employee’s actual functions
Identify the tasks the employee performs before choosing the training. General awareness, function-specific, safety and security-awareness training address different requirements. In-depth security training applies where the security-plan rule requires it. A driver, loader and employee preparing shipping papers may need different function-specific instruction. An attendance list alone does not explain the functions covered or establish the required testing and employer certification.
A change in duties needs a training review
An employee trained for one task begins classifying materials or preparing shipping papers. Compare the new duties with the existing training and determine what additional instruction and testing apply before relying on the old record. Section 172.704 allows certain new or changed-function work under the required direct supervision while initial training is completed within ninety days. It is not a universal permission for unsupervised work. Recurrent training is required at least once every three years.
Official source
Confirm applicability, exceptions, and current requirements for your operation. This is a focused summary.
