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IMDG Code Training Requirements in the United States: What Employers Need to Know

September 15, 2026 by SafetyNet

Companies in the United States that ship dangerous goods by sea operate within an international transportation system. A container may be packed at a warehouse in Ohio, transported by truck to a port in New Jersey, loaded onto an ocean vessel and eventually delivered to a customer in Europe, Asia or South America. Throughout that journey, different regulatory systems can apply. For the maritime part of the transport chain, one of the most important is the International Maritime Dangerous Goods Code, better known as the IMDG Code.

For U.S. companies, however, compliance with the IMDG Code should not be viewed separately from the U.S. Hazardous Materials Regulations. Employees involved in preparing hazardous materials for ocean transport may have training obligations under both the IMDG Code and Title 49 of the Code of Federal Regulations. Understanding how these requirements interact is therefore essential for shippers, freight forwarders, warehouses, consolidators, container packing facilities and other organizations involved in international maritime transportation.

Why IMDG training is required

The IMDG Code establishes internationally recognized requirements for transporting dangerous goods by sea. Its provisions address subjects including classification, packaging, marking and labeling, documentation, container packing, segregation, stowage and emergency response.

Chapter 1.3 of the IMDG Code specifically addresses the training of shore-based personnel. The principle is straightforward: personnel involved in transporting dangerous goods intended for carriage by sea must receive training appropriate to their responsibilities.

This obligation covers considerably more than employees physically loading containers. The IMDG Code identifies numerous activities that can bring personnel within its training framework. These include classifying dangerous goods, selecting proper shipping names, packing dangerous goods, marking and labeling packages, placarding cargo transport units, preparing dangerous goods documentation, offering dangerous goods for transport and loading or unloading cargo transport units.

Personnel involved in preparing loading or stowage plans, accepting dangerous goods for transport, handling dangerous goods during transport and carrying out compliance inspections can also require appropriate training.

The important principle is that training should correspond with the employee’s actual responsibilities. An employee preparing dangerous goods documentation requires different detailed knowledge from someone whose task is to mark packages or load a freight container.

The connection with U.S. 49 CFR requirements

For American companies, the IMDG Code is only part of the regulatory picture. The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration, or PHMSA, regulates hazardous materials transportation under the Hazardous Materials Regulations.

The federal hazmat training requirements are primarily contained in 49 CFR Part 172, Subpart H, including §§172.700 through 172.704. PHMSA states that hazmat employers must train, test and certify their hazmat employees and maintain the required training records.

The definition of a hazmat employee is deliberately broad. It is based primarily on the functions an individual performs rather than their job title. Employees who load, unload or handle hazardous materials, prepare hazardous materials for transportation, inspect packaging or perform other functions that directly affect hazardous materials transportation safety can fall within the definition.

Consequently, an employee working for an American company may be subject to U.S. hazmat training requirements even when the shipment is ultimately being prepared in accordance with the IMDG Code.

This is particularly relevant because 49 CFR permits the use of certain international standards for international shipments. When the IMDG Code is used under the authorization provided by the HMR, the employee must understand the international requirements applicable to the function being performed.

PHMSA has specifically addressed this relationship. The agency has explained that training conducted to comply with the IMDG Code may be used to satisfy applicable 49 CFR training requirements to the extent that the training covers the components required by §172.704. If the IMDG training does not cover all applicable HMR requirements, additional training must be provided.

In practical terms, an IMDG certificate by itself should therefore not automatically be interpreted as proof that every U.S. DOT training requirement has been satisfied.

What training must U.S. hazmat employees receive?

Under 49 CFR §172.704, required hazmat employee training includes several elements. Employees must receive general awareness and familiarization training so they can recognize hazardous materials and understand the general structure of the regulations. They must also receive function-specific training covering the regulatory requirements applicable to the tasks they actually perform.

Safety training is another component and addresses subjects such as emergency response information, measures to protect employees from hazards and methods for preventing accidents. Security awareness training is required as part of the federal training framework, while employees working under a required hazardous materials security plan may also need in-depth security training. Depending on the employee’s responsibilities and transportation mode, additional modal or specialized training requirements can apply.

For an employee preparing an ocean shipment, function-specific training may therefore need to include IMDG requirements concerning matters such as classification, packaging, marks and labels, marine pollutants, dangerous goods documentation, segregation and container placarding.

This function-based approach is particularly important for companies purchasing online training. A general IMDG awareness course can provide an excellent foundation, but general awareness should not automatically be confused with complete function-specific qualification for every dangerous goods activity.

A person responsible only for recognizing dangerous goods may need a different level of training from a dangerous goods specialist responsible for classifying chemicals, selecting packaging and signing shipping documentation.

Training before performing dangerous goods functions

The IMDG Code states that shore-based employees should be trained in accordance with Chapter 1.3 before assuming responsibilities. Where required training has not yet been provided, functions should only be performed under the direct supervision of a trained person. The Code also calls for refresher training to account for regulatory and practical changes.

The U.S. HMR contains a related but distinct rule. PHMSA allows a new hazmat employee, or an employee who changes job functions, to perform regulated functions before completing training for up to 90 days, but only when working under the direct supervision of a properly trained and knowledgeable hazmat employee. Required training must be completed within that period.

Companies should therefore be careful not to assume that the U.S. 90-day provision eliminates the need to consider the requirements of an international code being used for a particular shipment.

Refresher training and regulatory changes

There is another important difference that deserves attention. Under 49 CFR, recurrent hazmat employee training is generally required at least once every three years. PHMSA also requires employers to maintain current training records, including information concerning the employee, completion date, training materials, trainer and certification of training and testing.

The IMDG Code requires training to be periodically supplemented with refresher training so personnel remain familiar with changes in regulations and practice. Because the IMDG Code is regularly amended, companies involved in maritime dangerous goods transportation should not simply wait for a calendar-based retraining date when a regulatory change directly affects an employee’s work.

PHMSA has addressed exactly this situation. When an amendment to the IMDG Code changes requirements relevant to a hazmat employee’s function, the employer does not necessarily have to repeat the entire training program immediately. However, the employee must receive the instruction necessary to understand the new or revised requirement. The normal three-year U.S. recurrent training cycle remains applicable.

This makes regulatory update training an important part of a robust dangerous goods training program.

Training records are part of compliance

Training is not complete simply because an employee attended a course. Under the U.S. system, the employer carries significant responsibility for demonstrating compliance.

PHMSA requires hazmat employers to train and test employees, certify that the required training has been completed and maintain records of current training. These records must be retained during employment and for 90 days thereafter, covering the current training cycle and the preceding three years as applicable.

Employers should therefore maintain a structured training matrix identifying which employees perform regulated dangerous goods functions, which modes of transport are involved and which training modules apply to each role.

For businesses shipping dangerous goods internationally, this matrix might combine general U.S. DOT hazmat training with specific modules covering highway, vessel, IMDG, air or other applicable requirements.

IMDG training as part of a U.S. compliance program

For American exporters and logistics companies, the most effective approach is to stop thinking about IMDG and 49 CFR as two completely separate training systems. They overlap, but they are not identical.

A warehouse employee packing dangerous goods into an ocean container may need knowledge of the IMDG Code while simultaneously performing functions regulated under the U.S. HMR. A shipping specialist preparing documentation may need detailed knowledge of both systems. A freight forwarder accepting dangerous goods from customers must understand which requirements apply before cargo reaches the vessel.

The employer should begin by identifying the functions each employee performs. From there, the required general awareness, function-specific, safety, security and modal training can be determined.

This approach does more than satisfy a regulatory requirement. Proper training reduces the likelihood of incorrect classification, incompatible cargo being loaded together, missing marks and labels, rejected containers, incorrect documentation and dangerous incidents during transportation.

For U.S. companies participating in international maritime trade, IMDG knowledge is therefore not simply an additional qualification. When employees prepare, offer, handle or document dangerous goods for ocean transportation, appropriate IMDG training can form an essential part of the company’s wider U.S. hazardous materials compliance program.

Who Needs IATA Dangerous Goods Training in the USA?

September 14, 2026 by SafetyNet

Many U.S. companies associate IATA Dangerous Goods Training primarily with airlines and specialized air cargo operators. In practice, the need for dangerous goods knowledge begins much earlier in the supply chain. Manufacturers, warehouses, freight forwarders, laboratories, e-commerce companies, distributors and even returns departments can all have employees whose work affects the transportation of dangerous goods by air.

A shipment does not become a dangerous goods shipment when it reaches the airport. Decisions made hours or even days earlier can determine whether the shipment is compliant. Someone may have classified the product, selected the packaging, applied labels, prepared documentation or simply decided that an item could be shipped as ordinary cargo. If that decision is wrong, the consequences may follow the shipment all the way to the aircraft.

For American employers, there is an additional consideration. International air transportation requirements operate alongside the U.S. Hazardous Materials Regulations in Title 49 of the Code of Federal Regulations. This means that companies need to understand not only IATA Dangerous Goods Regulations but also how dangerous goods training fits within their obligations under U.S. law.

It is the function, not the job title, that matters

One of the most important principles in dangerous goods training is that job titles alone do not determine training needs.

An employee does not have to be called a “Dangerous Goods Specialist” to perform a function that affects hazardous materials transportation. A warehouse associate, shipping coordinator, logistics manager, laboratory technician or customer service employee can make decisions that directly influence whether dangerous goods are transported correctly. Under the U.S. Hazardous Materials Regulations, hazmat employee training is largely function-based. Employees who perform regulated hazardous materials functions must receive training appropriate to those functions.

The same practical principle is increasingly central to dangerous goods training in aviation. Training should reflect what employees actually do. Consider a company that manufactures electronic equipment. One employee may package products containing lithium batteries. Another prepares shipping documentation. A third books the shipment with an air carrier, while an employee in the returns department receives damaged battery-powered equipment from customers.

All four employees may interact with dangerous goods, but their responsibilities are different. Their training requirements may therefore also be different.

Shippers preparing dangerous goods for air transport

Employees who prepare dangerous goods shipments are among the most obvious groups requiring appropriate training. Their activities may include identifying dangerous goods, determining the correct classification, selecting the proper shipping name and UN number, determining permitted quantities, selecting packaging, applying marks and labels and preparing dangerous goods documentation. These are not administrative details. They are safety controls.

Air transportation places particularly strict limitations on certain dangerous goods. Some materials may be permitted aboard cargo aircraft but prohibited aboard passenger aircraft. Quantity limits can vary according to packaging and aircraft type, while certain substances or articles may be prohibited from air transportation altogether. Employees making these decisions therefore require sufficient function-specific knowledge to perform them correctly. A general IATA Dangerous Goods Awareness course can provide valuable foundational knowledge, but employers should distinguish awareness from qualification to independently perform complex dangerous goods functions.

Warehouse and fulfillment center employees

Warehouses are another important group. A warehouse employee may never complete a Shipper’s Declaration, but that does not mean dangerous goods training is irrelevant. Employees may receive packages carrying hazard labels, prepare orders containing regulated products, consolidate shipments, apply handling marks or transfer goods into an air freight stream. Recognition is particularly important. Products that appear ordinary can contain dangerous goods. Aerosols, perfumes, paints, adhesives, cleaning products, chemicals, batteries and equipment containing batteries are common examples. An employee who does not recognize that a product may be regulated can unintentionally bypass the company’s dangerous goods procedures. Awareness training can therefore be highly relevant for warehouse personnel whose responsibility is to recognize potential dangerous goods and refer them to appropriately trained specialists.

Freight forwarders and logistics providers

Freight forwarders occupy an important position between shippers and air carriers. Depending on the services they provide, their employees may receive dangerous goods documentation, inspect packages, consolidate cargo, prepare transport documentation or arrange transportation with an airline. The required training should reflect those functions. An employee who only receives initial booking information may require a different competency level from an employee responsible for accepting a fully regulated dangerous goods shipment.

For logistics companies handling multiple modes of transportation, the training analysis becomes even more important. The same employee may encounter road, ocean and air transportation requirements during a single working day. A shipment moving from a U.S. manufacturer to an overseas customer may begin under U.S. highway requirements before continuing under international aviation requirements. Employees need to understand which rules apply to the functions for which they are responsible.

Lithium batteries have dramatically expanded the audience

Lithium batteries are one of the clearest reasons why dangerous goods awareness is no longer relevant only to traditional chemical companies. Modern commerce depends on battery-powered products. Laptops, mobile phones, power tools, medical devices, measurement equipment, cameras, industrial equipment and countless consumer products contain lithium batteries.

Different regulatory provisions can apply depending on whether batteries are shipped alone, packed with equipment or contained in equipment. Battery type, capacity, condition and packaging configuration can also affect the requirements. This creates potential dangerous goods responsibilities in organizations that may not think of themselves as hazmat shippers. E-commerce businesses are a good example. A fulfillment center may handle thousands of consumer products, only some of which contain regulated batteries. Employees responsible for receiving, picking, packing and returning those products need procedures that prevent regulated batteries from accidentally entering the air transportation system as ordinary cargo.

Returns operations deserve particular attention because a battery that was safe when originally sold may return damaged, swollen, defective or subject to a safety recall. Such conditions can significantly affect whether and how it may be transported. Awareness training helps employees recognize when specialist intervention is required.

Laboratories, healthcare and technical companies

Another frequently overlooked group consists of laboratories, healthcare organizations, research facilities and technical companies. These organizations may occasionally ship samples, diagnostic specimens, chemicals, dry ice, battery-powered equipment or other regulated materials. Because dangerous goods shipping may not be their primary business activity, employees can underestimate the regulatory requirements. Occasional shipments do not automatically mean that training is unnecessary.

If an employee performs a regulated hazardous materials transportation function, the frequency with which that function is performed does not remove the need for appropriate knowledge and training. This is particularly important where employees prepare shipments themselves rather than transferring the entire preparation process to a specialist dangerous goods provider.

What should IATA awareness training cover?

Awareness training should give employees a practical understanding of the dangerous goods system and enable them to recognize when additional requirements apply. Depending on the employee’s role, introductory training can address the nine hazard classes, UN numbers, proper shipping names, hazard labels, marks, packaging concepts and basic documentation principles. Employees should also understand why air transportation imposes additional restrictions and why apparently small errors can have serious consequences. Lithium batteries, hidden dangerous goods and undeclared shipments deserve particular attention because employees outside traditional dangerous goods departments frequently encounter them. The objective is not to turn every warehouse employee into a dangerous goods specialist. The objective is to make sure employees know enough to recognize the limits of their responsibilities. A well-trained employee should understand when a shipment can proceed according to established procedures and when it must be stopped and referred to someone with more specialized dangerous goods knowledge.

IATA training does not replace every 49 CFR requirement

This distinction is especially important for U.S. employers. Hazardous materials transportation in the United States is subject to the Hazardous Materials Regulations. Under 49 CFR Part 172, Subpart H, hazmat employers have responsibilities concerning the training, testing and certification of hazmat employees. Training under 49 CFR §172.704 includes general awareness and familiarization, function-specific training, safety training and security awareness training. In certain circumstances, in-depth security training is also required.

Air transportation also introduces modal requirements. An IATA Dangerous Goods course may cover substantial portions of the knowledge an employee needs, but employers should not simply assume that possession of an IATA training certificate satisfies every requirement imposed by U.S. law. Instead, the employer should compare the training received with the functions performed by the employee and the applicable U.S. requirements. Where gaps exist, additional training should be provided. For many organizations, this means combining IATA-focused training with appropriate U.S. DOT 49 CFR hazmat training.

Awareness versus function-specific training

This is perhaps the most important distinction for employers choosing a course. Awareness training is appropriate where employees need to recognize dangerous goods, understand the basic regulatory system and know how to respond when potentially regulated materials are encountered. It should not automatically be considered sufficient for every employee who prepares dangerous goods shipments.

An employee responsible for determining whether a chemical meets a particular classification criterion requires deeper knowledge. The same applies to employees selecting packing instructions, preparing regulated documentation or making decisions concerning complex lithium battery shipments. Employers should therefore map their employees according to their actual responsibilities.

For a relatively simple organization, this might mean dividing personnel into employees who need basic awareness, employees performing specific dangerous goods functions and dangerous goods specialists responsible for complex regulatory decisions. This creates a much stronger training system than assigning the same course to everyone.

A practical question for every U.S. employer

Companies can begin with a simple question: Can any of our employees cause dangerous goods to enter the air cargo system?

If the answer is yes, the company should examine those employees’ functions. Who identifies the product? Who determines whether it is hazardous? Who packs it? Who applies the labels and marks? Who prepares the shipping documents? Who books the shipment? Who handles lithium battery returns? Who decides whether an apparently ordinary product can travel by air?

Those questions often reveal training needs that were previously overlooked. For many employees, IATA Dangerous Goods Awareness Training is the appropriate starting point. For employees performing regulated shipping functions, additional function-specific training may be necessary. U.S. employers must also ensure that applicable 49 CFR training requirements are satisfied. The result should be a training program based not on job titles or certificates, but on actual responsibilities. In air cargo, the first safety decision is often made long before the aircraft leaves the ground. Making sure that the person making that decision has the right knowledge is one of the most effective ways to prevent undeclared dangerous goods, rejected shipments and potentially serious incidents.