No. DOT Subpart H allows oral tests and skills checks. PHMSA says these methods must show the worker can do the assigned job under the hazmat rules. PHMSA training FAQ, Q9
Start with the task you need to assess
The employer must test each worker on the required subjects. It must use a suitable method. The rule does not require the same written quiz for all staff. §172.702(d)
For example, ask a shipping-paper worker to review a sample. Can they find and explain the errors? For another task, a supervised skills check may fit. These are suggested test ideas. They are not federal test scripts. Choose a method that shows what the worker can do.
Competence is the purpose of the test
PHMSA does not require a set test document. A written test, oral test or skills check can work. Each must show that the worker can do the job. PHMSA Q9
PHMSA limits what you can certify. The worker must be able to perform the assigned duties. If a worker cannot show a skill, we suggest more teaching. Then test that skill again before you certify it. PHMSA Q9
Keep a usable record of the result
The training file must certify that the worker was trained and tested. It must also identify the materials used. Give a description, copy or location. An oral test still needs this record. §172.704(d)(3), (5)
We suggest a short note from the person who tests the worker. Name the task, date, method and follow-up. This helps explain the result. It is not a required federal form. It does not replace the full training record.
Can a demonstration replace the instruction?
No. PHMSA says passing an exam does not waive training. That applies to initial and recurrent training. A choice of test format does not remove the need to teach. PHMSA Q10
This answer covers DOT Subpart H. A state license or other program may have its own exam rules. Check those rules too. Keep each program clear in your written procedure.
About Bill Stomp
Bill Stomp ran 87+ propane branches in 12 states and helped 200+ propane companies. He was VP of sales and marketing for a multi-state fuel company.
Put it in writing
See the Propane Policies and Procedures Manual. Ask about documenting your assessment procedure within its published training and recordkeeping scope.
General information, not legal advice. Sources read October 17, 2026. This answer addresses the federal hazardous materials transportation rules; check separate state and other applicable requirements.