Clarification on Completion Reports and Certificates for Shipping and Transport of Regulated Biological Materials Training

CITI Program’s Shipping and Transport of Regulated Biological Materials course provides introductory information on certain aspects of International Air Transport Association (IATA) and U.S. Department of Transportation (DOT) regulations. However, this course does not provide certification that meets the full IATA training requirements for shipping infectious substances by air, except for exempt human or animal specimens (for which no formal dangerous goods training is mandated).

The course can assist learners in preparing to ship lower-risk materials, such as exempt specimens, and provides a basic familiarization with the requirements for moderate-risk Category B infectious substances (UN 3373). It does not provide the comprehensive, competency-assessed, function-specific training required by IATA for personnel shipping Category B substances by air. IATA regulations mandate documented training tailored to job functions, with recurrent training every 24 months and employer verification of competency. The CITI Program course alone is not sufficient to satisfy these requirements for Category B air shipments—additional specialized training from an IATA-recognized provider is strongly recommended.

The course also reviews high-level requirements for shipping high-risk Category A infectious substances. It does not provide the detailed instruction, hands-on competency assessment, or assurance needed to meet IATA (or DOT) training requirements for Category A shipments. Individuals intending to ship Category A infectious substances (high-consequence human or animal pathogens) must not rely on this course and should immediately contact their organization's safety office or biosafety officer for approved, site-specific training before any shipment.

Notably, DOT regulations (49 CFR 172.704(d)) require specific elements in training records, including certification that the employee has been trained and tested. IATA has similar stringent documentation and competency expectations.

Given these regulatory demands, CITI Program’s completion reports and certificates for this course do not include any statement certifying that a learner has been fully trained, tested, or deemed competent under DOT Subpart H (49 CFR 172.700–704) or IATA Dangerous Goods Regulations. While organizations may choose to use this course as supplemental material for general awareness or basic familiarization (particularly for exempt specimens or ground-only shipments), it does not meet all required elements—such as in-depth function-specific training, safety/security training, competency testing, or recurrent certification—for shipping Category A or Category B infectious substances.

Employers remain solely responsible for ensuring all regulatory training requirements are met, including any organization-specific needs. Only the employer can certify an employee as fully trained and competent. For air transport under IATA, we strongly advise consulting IATA-approved training providers, reviewing the current IATA Dangerous Goods Regulations, and verifying acceptance with your air carrier prior to any shipment involving Category A or Category B materials. For exempt specimens only, proper packaging knowledge from this course may be helpful, as no formal dangerous goods certification is required.

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