Yes, if a new or changed DOT hazmat rule affects the worker’s job. PHMSA says to teach the change in time to meet that rule. Do not wait for the three-year refresher. PHMSA training FAQ, Q12
Read the compliance date with the change
The employer must thoroughly teach the rules for the worker’s tasks. A future refresher date does not teach a rule that takes effect sooner. §172.702(b)
For a change review, we suggest noting the changed section. List the affected work, compliance date and person in charge. Use the actual rule’s timeline. This page sets no fixed number of days for all changes.
Find the people whose work is affected
Task-specific lessons must cover the rules for the worker’s job. Compare the rule change with the task. Then identify who does that work. §172.704(a)(2)(i)
Suppose a change affects a shipping-paper duty. Start with that duty and its lesson. This is a workflow example. It does not mean a shipping-paper rule changed today.
We suggest giving the trainer both the new work procedure and source rule. Have the safety lead check them. The lesson and written work steps should agree.
Keep the recurring cycle on the calendar
Section 172.704(c)(2) requires recurrent training at least once every three years. PHMSA also says to teach relevant rule changes on their own compliance timelines. §172.704(c)(2) PHMSA Q12
A short update may cover only one topic. Check it against the full recurrent program. Describe training as complete only when the content supports that.
Test and identify the revised material
The employer must test staff on the required subjects by suitable means. The file must identify the materials used. It must also certify that the worker was trained and tested. §172.702(d) §172.704(d)(3), (5)
We suggest saving the lesson version with the work procedure revision. A later reviewer can then see what was taught.
Give rule monitoring an owner
Your manual can name who watches for rule changes. It can assign the review of affected jobs and the training. Aim to have the work steps and lesson ready on time.
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 how the listed training and recordkeeping content can assign ownership of regulatory-change instruction.
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.