Hazmat Employee Training Requirements: Teaching Teams To Handle Risk The Right Way

Training is not optional when you ship hazmat

If your products involve batteries, flammables, aerosols, coatings, or chemicals, you are not just shipping goods. Under U.S. law, you are offering hazardous materials into transportation. That simple fact triggers hazmat employee training requirements that sit in federal regulations, not in fine print from carriers.

The U.S. Department of Transportation writes these rules in the Hazardous Materials Regulations, especially 49 CFR Part 172, Subpart H (sections 172.700 through 172.704). Those sections say that any hazmat employee has to be trained, tested, and documented before they perform functions that affect the safe transportation of hazardous materials, and that training has to be repeated on a regular schedule.

In plain terms, if someone in your chain picks, packs, labels, loads, or prepares documents for hazmat shipments, federal rules expect that person to know what they are doing. Watching a five minute video and guessing is not enough.

Who counts as a hazmat employee

One of the most misunderstood parts of the regulations is the definition of a hazmat employee. It is much broader than people think.

Under 49 CFR 171.8, a hazmat employee is anyone who directly affects hazardous materials transportation safety. That includes people who classify materials, select packaging, mark and label packages, prepare shipping papers, load or unload vehicles, and operate vehicles that carry hazmat.

Director of Vendor Operations Kay Hillmann sees how wide that net really is in a modern 3PL. She works with everything from matches and paint to generators and perfumes. "We are certified in all hazardous materials. We were looking at a matches company, that is a hazardous material. We ship concrete sealant, that is hazardous, a different classification. Paint, your everyday paint you get from a home center, that is hazardous material. Flammables, like gas power generators, that is hazardous material. Perfumes, alcohol."

Every person who handles those products in a way that affects shipping safety falls under the hazmat employee definition. That means warehouse associates, leads, supervisors, shipping clerks, and sometimes even customer service staff who help prepare shipping instructions.

What the law expects you to teach

DOT does not leave training content to guesswork. In 49 CFR 172.704, they lay out specific types of training that must be covered.

First, general awareness and familiarization. Employees must understand that hazardous materials exist in the operation, recognize basic hazard classes, and know that there are rules governing how those materials move.

Second, function specific training. Each person must be trained on the requirements that apply to the actual job functions they perform. Someone who builds pallets needs different detail than someone who signs shipping papers or designs packaging.

Third, safety training. Employees must learn how to protect themselves and others from the hazards they work around. That includes safe handling, emergency response basics, and procedures for dealing with incidents like leaks or damaged packages.

Fourth, security awareness. Employees must be made aware of the security risks associated with hazardous materials transportation and methods to enhance security.

For some operations, there is also in-depth security training if a written security plan is required under 49 CFR 172.800.

Director of Vendor Operations Kay sums up the core responsibility this way: "You have to make sure that you are doing correct classification of hazardous material. If it is lithium battery, flammable, toxic, whatever the case might be, you have to make sure you are shipping it in the right containers." Training is how that knowledge gets into the minds and habits of the people doing the work.

How often hazmat employees must be trained

Hazmat employee training is not a one-and-done task. DOT requires initial training and then recurrent training at least once every three years, or sooner if regulations or job functions change in ways that affect safety.

New hazmat employees can work under direct supervision for a short period before completing training, but they must be fully trained within 90 days of employment or reassignment to hazmat duties. After that, recurrent training has to refresh their knowledge and update them on regulatory changes.

That schedule matters in high growth environments. New products, new customers, and new shipping patterns mean new risks. A training program that barely keeps up with hiring will always be behind on hazard awareness.

Documentation: proving you did the work

DOT regulations do not just care that training occurred. They care that you can prove it. Under 49 CFR 172.704(d), hazmat employers must keep records of each hazmat employee's training.

Those records must include the employee's name, the completion date of the most recent training, a description or copy of the training materials, the name and address of the trainer or training provider, and a certification that the employee has been trained and tested.

From a practical standpoint, that means a hazmat focused 3PL has to maintain a living training file. Every time someone is hired, promoted, or moves into a role with hazmat responsibilities, their records need to be updated. Every time regulations or internal procedures change, training materials and records need to be refreshed.

G10 takes that responsibility seriously. Kay explains that they went to the national experts to build their program. "We have been certified by the expert in the country on hazardous materials in all classifications." She is referring to GSI Training Services and its founder, who works closely with regulators and major shippers like Amazon to keep training aligned with current rules.

Why training is a cornerstone of carrier approvals

Carriers are on the hook for safety in their networks, so they care deeply about who is preparing the hazmat they haul. Many carrier hazardous goods approvals depend on proof that a shipper has robust training programs in place.

Director of Business Development Matt Bradbury explains why so many providers shy away from hazmat, especially higher watt hour batteries. "Even our competition, they do not want to touch things that are over 40 or 45 watt hour batteries. Our largest competitor, where I come from, will not touch anything over 40 watt hours."

G10 chose to invest in training and certifications so carriers would be comfortable moving complex products. Matt says, "There is a big space between like 40, 50 watt hours and 100 watt hours that we can also do no problem, because we have all the certifications for large hazmat."

Carriers can see the difference between a shipper with paper-thin training and one with a real program. Fewer documentation mistakes, fewer leaking packages, and fewer incidents all point to employees who know what they are doing.

Culture matters as much as curriculum

Good hazmat training is not just slides and quizzes. It is a culture that treats safety and compliance as part of daily work, not as an annoying side quest.

CTO and COO Bryan Wright talks about the people side at G10. "I think that just comes to being fair with people, understanding, and just being a person. Caring about your employees." When people feel respected and supported, they are more likely to speak up when something does not look right.

Director of Operations and Projects Maureen Milligan describes G10's culture as "ground up," with a focus on listening to ideas from the warehouse floor. "Just because you happen to work in a warehouse does not mean that your idea is not valid." In a hazmat context, that means employees feel comfortable saying, this container looks wrong, this label is missing, or this drum does not match the paperwork.

VP of Customer Experience Joel Malmquist sees how this plays out under pressure. He describes employees going above and beyond to help merchants in crunch situations, like when social media drives an unexpected order spike. That kind of commitment goes hand in hand with a culture where people will also stop the line if something is unsafe.

Systems that reinforce what people learn

Training sets expectations. Systems make it easier to live up to them.

Bryan explains that a strong warehouse management system is part of G10's safety backbone. "A good WMS tracks inventory through the warehouse at every point that you touch it." For hazmat, that system also tracks hazard classes, packaging rules, label formats, and carrier selection logic.

Because Bryan and his team built the WMS, they can encode hazmat business rules directly. If a certain SKU requires a specific UN rated box, the system can enforce that. If a carrier will not accept a certain battery configuration, the system can route those orders differently. When regulators or carriers change requirements, configuration gets updated so employees are not relying on memory alone.

That combination of trained people and smart systems is what regulators want to see. You are not just teaching people the rules once and hoping they remember. You are designing work so that doing the right thing is the path of least resistance.

What this means for brands that are growing into hazmat

For many brands, building a full hazmat training program in house is not realistic. They have enough on their plate designing products, managing suppliers, and growing sales. But they still own the risk when their products are hazardous, whether they keep logistics in house or work with a 3PL.

Kay is clear about that responsibility. "You are liable, as the shipper, to make sure it is packaged correctly. If you do not, there are fines that can be involved. You can get shut down by the shippers themselves and by the DOT." Training is the first line of defense against that outcome.

Working with a 3PL that already meets hazmat employee training requirements is one way to manage that risk. It lets you plug into a system where employees are already trained on classification, packaging, documentation, and carrier rules, and where training records are maintained in line with 49 CFR 172.704.

Steps to take before your next hazmat move

If your product line already includes hazardous materials, or you expect it will in the next year, this is the right time to ask harder questions about hazmat employee training.

Ask your internal team or your 3PL how they define a hazmat employee. Check whether training content covers general awareness, function specific duties, safety, and security, as the regulations require. Confirm how often training is repeated and how records are kept. Make sure someone in the operation is staying current with changes to the Hazardous Materials Regulations and carrier rules.

As Kay puts it, "We follow regulations and guidelines to a T because we want to make sure that we are doing it legally, correctly, and safely." That mindset, backed by real training and documentation, is what keeps regulators, carriers, and customers comfortable as your hazmat volume grows.

If your products are crossing into hazmat territory, or already there, talk with G10 about how their hazmat employee training program can help you ship with confidence instead of crossing your fingers.