With all of the safety and environmental training that needs to be done and all of the plans that EHS managers need to maintain and update, it can be easy to overlook Department of Transportation (DOT) training requirements – especially when most of the staff isn’t actually working on a loading dock shipping products. But, facilities that offer hazardous materials for shipment need to be aware of DOT training requirements for anyone onsite that is involved with the shipment of hazardous materials and ensure that employees are properly trained.
If employees at your facility perform any of the following functions, the DOT considers them to be “hazmat employees” [49 CFR 171.1]:
- Determining the hazard class of a material, assigning a packing group, filling out shipping papers or providing placards to a transporter
- Selecting hazmat packaging
- Packaging materials into bulk or non-bulk packaging
- Securing closures on a hazardous materials package or container
- Adding labels or markings to a container to indicate that it contains a hazardous material
- Selecting a mode of transportation
- Loading, blocking or bracing hazmat packaging into a freight container or transport vehicle
The amount of training required depends on the employee’s actual level of involvement, but at a minimum, all hazmat employees must receive a general awareness training to help them become familiar with hazardous material transportation requirements and be able to identify hazardous materials being prepared for transportation [40 CFR 172.704]. Hazmat employees may also need:
- Function-specific training covers regulations pertaining to specific job functions.
- Safety training discusses how the employee will be protected from hazards. The emergency response information in 49 CFR 172.600 must also be covered as part of safety training.
- Security awareness training provides an awareness of risks associated with transporting hazardous materials. This training is required within 90 days of employment or assignment and Methods for recognizing and responding to possible security threats must also be discussed.
- In-depth security training teaches employees about company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure.
Training must occur before employees are assigned to any task that affects a hazardous materials shipment, and refresher trainings must occur at least once every three years, or when applicable regulations change.
You tell us: What else do you need to know about hazmat training? Let us know in the comment section below!