The subcontractor must train its own hazmat employees. It is their hazmat employer. Your company may help teach them. That help does not transfer the subcontractor’s employer duty. PHMSA training FAQ, Q17
Identify the actual employer first
This answer is about a subcontractor’s own staff. First, find out who employs the people doing the work. Staffing and contract terms can differ. Do not assume every arrangement has the same answer.
Each hazmat employer must ensure its own staff get the required training. PHMSA applies that rule to subcontractors in Q17. §172.702(a) PHMSA Q17
As a contracting step, we suggest writing down who employs the workers. Note who will teach each lesson. Have unclear employer terms reviewed before assigning work. A purchase order label alone does not decide legal status.
The employer and the instructor can differ
Training may come from the employer or another public or private source. The instructor and employer can be different parties. Arranging the lessons does not make the instructor the employer. §172.702(c)
Required content follows the worker’s tasks. Compare the planned duties with the lessons offered. Ask for the course scope. A course name alone does not show what it teaches. §172.704(a)(2)(i)
We suggest a note with the employer and instructor contacts. Add the company contact for site questions. Dispatch should be able to find who is in charge before the first job.
Do not stop at an attendance sheet
Each employer must test its staff by suitable means. The training file must also certify that the worker was trained and tested. §172.702(d) §172.704(d)(5)
Covered staff need in-depth lessons on the required security plan. Those lessons must teach how to carry it out. Review the duties and plan involved. An unrelated course may not teach your company’s steps. §172.704(a)(5)
Put the coordination in your manual
We suggest a written process for checking training before contractor work starts. Name who checks the terms and resolves missing details. The process does not replace either party’s transport duties. It helps the office ask the same useful questions each 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. Discuss a contractor-coordination procedure against the published training and records scope; confirm what your quote includes.
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.