DOT Part 172, Subpart H sets no single course length for all workers. The employer must make sure the lessons cover the assigned duties well enough. An eight-hour course label alone does not prove compliance. PHMSA Interpretation 03-0048
Plan from the duties, not the clock
A DOT interpretation dated May 21, 2003 addressed course length. It set no fixed time for training or testing. It left the employer to judge whether training was adequate. Read that guidance with the current rule. PHMSA 03-0048
The current rule requires training for the worker’s specific tasks. It must cover the rules for those tasks. Start your course review with a list of the work. §172.704(a)(2)(i)
We suggest asking each provider for a course outline. Ask which jobs it covers and how it tests learning. Compare those answers before you compare hours. A longer course still needs to cover each duty. Attendance alone does not show what was taught.
Include the required safety subjects
Safety lessons must cover emergency response information. They must also teach worker protection and ways to avoid accidents. Include the employer’s own measures to protect staff from exposure. §172.704(a)(3)
Workers covered by the in-depth security rule need more. They must learn the required company plan. Allow time for that content. Check whether the general course includes it. §172.704(a)(5)
Use the assessment to check the learning
The employer must use a suitable test. Time spent in class cannot replace it. §172.702(d)
For a course check, we suggest asking how each duty is taught. Ask how each will be tested too. Set the schedule from those answers. Leave time to teach a topic again if needed.
The file must certify that the worker was trained and tested. It must identify the materials used too. §172.704(d)(3), (5)
Does this settle state course hours?
No. This answer covers only federal Subpart H course length. Check any state license rules and other requirements. Check your employer’s program too. One course may serve more than one purpose. Review the content for each purpose.
Put that check in your written procedure. Name the person who makes it.
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. The product lists training and recordkeeping content. Discuss how your written procedure will evaluate course coverage.
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.