No. Passing a test does not waive DOT hazmat training or recurrent training. That holds for an experienced propane driver too. PHMSA treats the lessons and the test as separate duties. PHMSA training FAQ, Q10
Experience helps you plan the lesson
A longtime driver may know the route and equipment well. Use that knowledge to choose useful examples. The employer must still teach the rules for the driver’s tasks. §172.704(a)(2)(i)
For a refresher review, we suggest comparing current duties with the lesson outline. Use company work steps where they fit. Find weak areas early. Put time into useful teaching rather than a generic talk.
Keep both parts of the program
Subpart H requires recurrent training at least once every three years. Passing a test does not create an exception to that limit. §172.704(c)(2)
The employer must also test staff on the required subjects by suitable means. Meeting the testing duty does not cancel the teaching duty. §172.702(d) PHMSA Q10
We suggest putting the lesson and test on the same work order. Name who checks that both took place. Have them check before closing the file.
What can you certify?
PHMSA says you can certify only duties the worker can perform successfully. Years on the job do not prove a current test result. PHMSA Q9
The file must show the most recent training completion date. It must certify that the worker was trained and tested. A test score alone does not show that both took place. §172.704(d)(2), (5)
How should the written procedure handle veterans?
Give experienced staff useful lessons and a meaningful test. We suggest keeping an entry quiz from closing the file by itself. That keeps the teaching and testing duties clear.
A manual can name who schedules the refresher. It can assign the test and record check too. The company must carry out those steps.
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. Review the training and proof-of-training scope before asking for a written refresher procedure for your company.
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.