Altor guide · 2026-09-04

Initial vs recurrent DG training: who needs what and when

The certificate on the wall is three years old. The person who signs today's air declaration sat in that class. The freight is booked on an aircraft. The clock that governs that function already closed.

That is the training problem desks miss. They keep one folder, one date, and one course title, then treat everyone who sat in the room as current for every mode.

What the regulation actually requires

Who needs it is not a job title. It is a function.

A hazmat employee under 49 CFR 171.8 is a person who, in the course of employment, directly affects hazardous materials transportation safety. That includes people who prepare hazardous materials for transportation, load or handle them, or are responsible for the safety of transporting them. 49 CFR 171.1(b) lists the pre-transportation functions: class, packaging, marks, labels, and the shipping paper. Classifying a consignment and signing a Shipper's Declaration sit in that list. So does the warehouse clerk who applies the class 3 label.

The employer duty is 49 CFR 172.702. The hazmat employer trains each hazmat employee, instructs that employee in the requirements that apply to the function, and tests on those subjects. Except for the supervised window in 49 CFR 172.704(c)(1), 49 CFR 172.702(b) does not let someone perform the function without that instruction.

What they need is 49 CFR 172.704(a): general awareness, function specific training, safety training, and security awareness. In depth security training applies only when 49 CFR 172.800 requires a transportation security plan. Function specific is the piece that has to match the work. A general awareness course does not teach the passenger and cargo columns.

A worked example from the current table. UN 1090 Acetone, Class 3, packing group II. Passenger aircraft: packing instruction 353, 5 L per package. Cargo aircraft: packing instruction 364, 60 L per package. The person who writes that line has to be trained to read IATA DGR Section 4.2, lock the aircraft type from the booking, and complete the declaration to IATA DGR 8.1.6.

The 49 CFR clocks are initial and recurrent. Initial training must be completed within 90 days of employment or a change in job function, per 49 CFR 172.704(c)(1). Until then the employee may perform the function only under the direct supervision of a trained hazmat employee. Recurrent training is at least once every three years, per 49 CFR 172.704(c)(2). A change in job function restarts the initial clock for the new work.

Air is a shorter clock. IATA DGR 1.5 is the air training rule. ICAO TI Part 1, Chapter 4 requires recurrent training and assessment within 24 months of the previous training and assessment, and requires personnel to be trained before they perform the duty. The 90 day window in 49 CFR 172.704(c)(1) is a Hazardous Materials Regulations allowance. It is not an IATA window. If the person prepares or signs an air declaration, the 24 month clock is the one that counts.

Records are 49 CFR 172.704(d). Keep a current record covering the preceding three years: name, most recent completion date, the materials used, the trainer, and a certification that the employee was trained and tested. Keep it while that person is a hazmat employee, and for 90 days after. The names on those records have to match the signature line.

The mistake people make

Desks run one clock.

A 49 CFR recurrent that is still inside three years is treated as current for air. IATA DGR 1.5 already closed. The operator at the cargo terminal is not grading the highway cycle.

The 90 day window is treated as unsupervised time. 49 CFR 172.704(c)(1) requires a trained person at the elbow. A certificate issued on day 89 does not backfill the month the new hire packed and signed alone.

The folder holds certificates for people who no longer pack. The people who pack and sign are not on the 49 CFR 172.704(d) record. OSHA hazard communication is counted as function specific training. The forwarder's course is counted as the shipper's 49 CFR 172.702 duty. Dates get pulled from the hire anniversary instead of the last completion date. There is no test, even though 49 CFR 172.702 requires one.

When that paper hits IATA DGR 9.1.3, the discrepancy is a training finding as much as a description finding. Recovery after a rejection sits at https://altor.consulting/rejected.html.

How to fix it

Map the functions, then train the people who actually perform them.

List who classifies under 49 CFR 173.22, who packs, who marks and labels, who writes the shipping paper, and who signs under 49 CFR 172.204. Those people are hazmat employees. Train them under 49 CFR 172.702 and 49 CFR 172.704. For air, train them under IATA DGR 1.5 before they prepare or sign a declaration. Use the shorter clock. Do not wait for the three year 49 CFR date if the last air recurrent was 24 months ago.

Train to the function. The person who writes UN 1090 packing group II needs packing instruction 353 at 5 L on passenger aircraft, or packing instruction 364 at 60 L on cargo aircraft. Test. Keep the 49 CFR 172.704(d) record so it matches the signature line. If the job function changes, restart the initial clock for that function. If a previous employer's record covers this work, obtain it under 49 CFR 172.704(c)(3) and still confirm it is current for air.

A second set of eyes on a completed declaration is ordinary care. It is not a substitute for current training, and it is not a substitute for the signature.

Altor pre-checks completed Dangerous Goods Declarations line by line against the current regulations and returns a written report, with every finding cited, within one business day. You keep the pen. altor.consulting

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