DOT Training Requirements for Shipping Radioactive Materials

Why Training Comes First

If you're reading this guide, you're probably eager to learn how to classify your material, pick the right packaging, or fill out shipping papers—but keep in mind that shipper training is the key to doing this compliantly.

Here's the reality: DOT doesn't require you to pass a government exam or obtain a license to ship radioactive materials. What they do require is documented proof that you've been trained on the regulations that apply to your specific job functions. Without that documentation, every shipment you prepare is a violation—regardless of whether the shipment itself is perfectly compliant.

That being said, you don't need DOT or IATA training to use RadShip.com and this site is set up intentionally to help you navigate through the complex regulatory world of shipping radioactive material. Keep in mind that no matter what website application or software you use, you are the one certifying the package as compliant and you simply cannot be compliant unless you are trained per Subpart H.

Who Needs Training?

The “Hazmat Employee” Definition

Under 49 CFR 171.8, a “hazmat employee” is anyone who, in the course of employment, directly affects hazardous materials transportation safety. For radioactive materials, this includes anyone who:

• Determines the hazard class or proper shipping name
• Selects packaging for radioactive materials
• Fills or closes packages containing RAM
• Marks or labels packages
• Prepares shipping papers or dangerous goods declarations
• Loads or unloads RAM packages
• Operates vehicles transporting RAM
• Is responsible for RAM transportation safety
• Receives RAM shipments and performs required inspections

Who Doesn't Need Training?

If you only handle packages that have already been fully prepared by someone else and you perform no regulated function, you may not need hazmat training. However, in practice, most people who touch RAM shipments in any capacity fall under the definition.

The Four Required Training Components

DOT requires hazmat employees to receive training in four specific areas under 49 CFR 172.704(a):

1. General Awareness/Familiarization Training

This provides familiarity with the overall requirements of the Hazardous Materials Regulations (HMR) and enables employees to recognize and identify hazardous materials. For RAM shippers, this includes understanding:

• The nine hazard classes and where Class 7 (radioactive) fits
• Basic structure of the HMR (49 CFR Parts 171-180)
• How to use the Hazardous Materials Table
• The relationship between DOT, NRC, and IATA regulations

2. Function-Specific Training

This is training on the specific regulations that apply to the actual job functions you perform. A technologist who only receives packages needs different training than an RSO who prepares outgoing shipments. Function-specific training for RAM shippers typically covers:

• Classification of radioactive materials (49 CFR 173.403)
• Determining activity limits and package types
• Packaging requirements for your specific materials
• Marking, labeling, and placarding requirements
• Shipping paper preparation
• Vehicle loading requirements (if applicable)

3. Safety Training

Safety training covers emergency response information, self-protection measures, and accident prevention. For RAM, this includes:

• Understanding the emergency response information required by 49 CFR 172, Subpart G
• Measures to protect yourself from radiation exposure during normal operations
• Procedures for handling damaged or leaking packages
• What to do if an accident or spill occurs

4. Security Awareness Training

All hazmat employees must receive security awareness training that covers:

• Security risks associated with hazardous materials transportation
• Methods to enhance transportation security
• How to recognize potential security threats
• How to respond to security concerns

This must be completed within 90 days of employment for new hazmat employees.

5. Security Plan Training (If Applicable)

If your organization is required to have a security plan under 49 CFR 172, Subpart I (which applies to certain quantities of RAM), employees covered by the plan need additional in-depth security training specific to your organization's procedures.

Additional Requirements for RAM Shippers

Beyond the basic DOT requirements, RAM shippers often need additional training:

NRC Requirements (10 CFR 71.5)

The NRC requires that licensees who transport licensed material, or who deliver licensed material to a carrier for transport, comply with DOT regulations. Under 10 CFR 71.5, this means maintaining training records and ensuring personnel are properly trained.

IATA Requirements (For Air Shipments)

If you ship radioactive materials by air, IATA Dangerous Goods Regulations apply. Key differences:

• Recurrent training every 2 years (not 3 years like DOT ground)
• Specific training on air transport restrictions
• Understanding of passenger vs. cargo aircraft limitations
• Competency-based training with specific learning objectives

Modal-Specific Training

49 CFR 172.700 requires training specific to the transportation mode you use:

• Highway: Vehicle operation, loading, segregation
• Air: IATA/ICAO requirements, aircraft limitations
• Rail: Rail-specific loading and documentation
• Vessel: IMDG Code requirements

Keep in mind that IATA (air) and DOT (mostly ground) regulations intentionally overlap but do have a few differences. It is a good idea to find trainings that either cover both or take them separately. RadShip.com is mostly geared to these two modes of transport.

Initial vs. Recurrent Training

Initial Training

New hazmat employees must complete training before performing hazmat functions. However, there's a 90-day grace period under 49 CFR 172.704(c):

• New employees CAN perform hazmat functions during their first 90 days
• BUT they must work under direct supervision of a properly trained employee
• Training must be completed within 90 days of hire or job change
• The supervising employee must be knowledgeable in the functions being performed

Recurrent Training

Training doesn't last forever. You must complete recurrent training:

When Training Must Be Repeated

Besides the regular recurrence schedule, training may need to be repeated when:

• Regulations change significantly
• Job functions change
• Performance issues indicate additional training is needed
• Moving from one mode to another (ground to air, for example)

If shipping both ground and air, many radioactive shippers simply take a training every year, toggling between DOT and IATA. This is a conservative approach and also assures knowledgeable staff.

Training Records: What You Must Keep

Under 49 CFR 172.704(d), employers must create and retain training records for each hazmat employee. Records must include:

Required Record Elements

1. Employee's name – Full legal name
2. Completion date – Of the most recent training
3. Training materials – Description, copy, or location of materials used
4. Trainer information – Name and address of person/organization providing training
5. Certification – Statement that the employee has been trained and tested

Retention Requirements

• Records must be kept for the current training period (3 years for ground, 2 years for air)
• Records must be retained for 90 days after employment ends
• Records must be available for inspection by DOT officials upon request

Acceptable Record Formats

DOT doesn't prescribe a specific format. Acceptable methods include:

• Paper certificates and files
• Electronic records and databases
• Learning management system (LMS) records
• Training provider certificates (as part of the record)

Most radioactive shipping courses do give out a certificate after completing a test at the end of the course. Typically, the certificate can be photocopied and saved digitally and/or a paper copy filed with the rest of the worker's trainings.

Testing Requirements

Yes, testing is required. Under 49 CFR 172.702(d), employers must ensure employees are “tested by appropriate means” on training subjects.

What DOT Requires

• Some form of assessment is mandatory
• No specific test format is prescribed
• Written, oral, or practical demonstration are all acceptable
• No minimum passing score is specified in regulations
• Employees must demonstrate competence to perform their duties

What This Means in Practice

While DOT doesn't mandate a written exam with an 80% passing score, the intent is clear: employees must demonstrate they understand and can apply what they learned. Most training providers include a written exam, and many organizations set their own passing standards.

Typically, most trainings will require a passing score of 80% to obtain a certificate but students that need a little extra help understanding the code may be given some extra tutelage to pass.

Penalties for Non-Compliance

Training violations are taken seriously by PHMSA. Under 49 U.S.C. 5123:

Civil Penalties

• Up to $96,624 per violation (adjusted periodically for inflation)
• Each day of a continuing violation is a separate offense
• Each improperly trained employee can be a separate violation

Criminal Penalties

• Willful violations can result in criminal prosecution
• Fines up to $500,000 for organizations
• Imprisonment up to 10 years for individuals in cases involving death

Real-World Enforcement

PHMSA regularly cites training violations during inspections. Common findings include:

• No training records on file
• Training records missing required elements
• Expired training (past the 3-year recurrence)
• Training that doesn't cover actual job functions
• No documentation of testing

Where to Get Training

Training can be provided by the employer or by third-party providers. Options include:

In-House Training

• Developed and delivered by your organization
• Must cover all required elements
• Can be customized to your specific operations
• Employer is responsible for ensuring adequacy

Third-Party Training Providers

Several organizations offer RAM-specific hazmat training. Most of the time this is the most cost-effective approach because most organizations do not have an expert Hazmat Shipper and/or the expertise to develop a course.

How RadShip.com Fits Into Your Training Program

RadShip.com isn't a substitute for required hazmat training—no application or software is—but once you're trained, RadShip.com helps you apply what you've learned correctly and consistently. That being said, students getting access on RadShip.com simultaneously may see an advantage, as the application can give students a feel for a shipping workflow and allow them to check their manual calculations.

What Training Teaches vs. What RadShip.com Does

Training gives you the knowledge. RadShip.com gives you the tools to apply those requirements without manual calculation errors. We also help you with the shipping paper requirements, turning hours of work into minutes. Try it free for 7 days.

The Right Order

1. First: Complete required DOT/IATA training
2. Then: Use RadShip.com to perform compliant calculations
3. Verify: Shipper does a review of the classification
4. BOL: Shipper generates compliant shipping documents
5. Marking and Labeling: The correct marking and labeling is applied to the package(s)
6. Certify: Shipper does a final review of the shipment and certifies the BOL/DGD
7. Always: Maintain your training currency

Common Questions

Can I ship RAM without training?

No. Preparing any shipment of radioactive materials without completing required training is a violation of federal law, regardless of whether the shipment itself is properly prepared.

My training covers general hazmat. Is that enough for RAM?

Probably not. General hazmat training typically doesn't include sufficient Class 7 (radioactive) specific content to satisfy function-specific training requirements for RAM shippers.

Does my NRC license cover training requirements?

No. NRC licensing and DOT training are separate requirements. Your NRC license authorizes you to possess and use radioactive materials. DOT training requirements apply to the transportation of those materials.

Can I train myself?

Technically, yes—employers can provide their own training. However, you need subject matter expertise, current regulatory knowledge, and the ability to document that training meets all requirements. For most organizations, third-party training is more practical.

What if I only receive shipments?

Receiving RAM shipments involves regulated functions (inspection, surveys, etc.). Employees who receive shipments need training appropriate to their functions under both DOT (49 CFR 172 Subpart H) and NRC (10 CFR 20.1906) requirements.

Summary: Your Training Checklist

Before shipping radioactive materials, ensure:

• ☐ All employees performing hazmat functions are identified
• ☐ Initial training completed (within 90 days for new employees)
• ☐ Training covers all four components (general awareness, function-specific, safety, security)
• ☐ Class 7 specific content included
• ☐ Modal-specific training completed (ground, air, etc.)
• ☐ Testing conducted and documented
• ☐ Training records created with all required elements
• ☐ Recurrent training tracked (3 years ground, 2 years air)
• ☐ Records retained properly

Regulatory References

DOT Training Requirements:

• 49 CFR 172.700 – Purpose and scope
• 49 CFR 172.702 – Applicability and responsibility for training
• 49 CFR 172.704 – Training requirements

NRC Requirements:

• 10 CFR 71.5 – Transportation of licensed material
• 10 CFR 20.1906 – Procedures for receiving and opening packages

IATA (Air Transport):

• IATA Dangerous Goods Regulations, Section 1.5 – Training

PHMSA Resources:

• Hazardous Materials Training Requirements FAQ
• Training Requirements for Industry