PHMSA sets no special trainer credential or minimum trainer qualifications under Subpart H. The trainer must be able to teach the rules that apply. Your company may provide the training in-house. §172.702(c) PHMSA training FAQ, Q7
Choose for the work they can teach
A management title alone does not show teaching skill. PHMSA says the trainer must be able to teach the required topics. The employer must thoroughly teach staff the rules for their tasks. PHMSA Q7 §172.702(b)
For a practical check, we suggest asking the trainer to explain a real task. Can they teach the rules behind it? Can they show the approved work steps? Can they check what the worker learned? This is a suggested review. It is not a federal instructor exam.
Keep teaching and testing together
The employer must test staff on the required subjects by suitable means. Hiring a speaker does not remove that duty. Neither does holding a meeting. §172.702(d)
Task-specific training must cover the rules for the worker’s actual job. A manager who teaches delivery paperwork may need help with another job’s rules. §172.704(a)(2)(i)
We suggest naming the training lead and any topics needing outside help. Decide who checks the finished file too. The training record must include the trainer’s name and address. §172.704(d)(4)
Does using an outside trainer transfer responsibility?
No. The employer remains responsible for compliance even when training is incomplete. An outside course may help. The employer still owns the duty. §172.704(c)(4)
Before buying a manual, assign both jobs. Who writes the training steps? Who teaches and tests the crew? Give your office an owner for each.
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 its published training and recordkeeping scope can put your instructor-selection process in writing.
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.