At the Dangerous Goods Advisory Council
39th Annual Summit last week in Crystal City, Virginia, representatives from the Pipeline and Hazardous Materials Safety Administration (PHMSA) spoke to a room full of DG professionals about the agency’s efforts to work with regulated shippers, freight forwarders, and carriers to bolster the safety of hazmat in transport.
During these presentations, PHMSA personnel stressed that hazmat training mistakes remain the #1 most common violation issued to shippers by DOT hazmat inspectors.
While training is the only HMR violation that carries a minimum
civil penalty—$471 per day, per employee—the real-world costs of allowing untrained employees to work with hazardous material far exceed the monetary penalty.
Besides a DOT training citation, the following can result from lack of hazmat training and hurt your business:
- Injuries on the job
- Returned or rejected shipments
- Fines for hazmat mistakes up to $78K per day, per violation
- Leaking packages and incidents in transit
- Releases to the environment that trigger CERCLA liability
- Emergency landings (air mode)
- Costly port delays
While hazmat training violations are common, not all training violations are the same. Here we’ll look at four specific
reasons hazmat shippers receive tickets or citations for training violations.
1. Failure to provide initial hazmat training
US DOT requires all hazmat employers to train hazmat employees on specific elements outlined in 49 CFR 172.704. Hazmat employees must be trained within 90 days of starting a hazmat job. Employees must receive update training when regulatory changes or a change in position affects their hazmat responsibilities. All hazmat employee training must—at a minimum—cover the following three elements: General awareness [49 CFR 172.704(a)(1)]
---familiarizes the employee with the requirements of the Hazardous Materials Regulations (HMR). General awareness hazmat training also covers how to recognize and identify hazardous materials in the workplace. Security awareness [49 CFR 172.704(a)(4)]
—this training must provide awareness of security risks inherent in hazmat transport and how to recognize and respond to security threats that may arise. Function-specific training [49 CFR 172.704(a)(2)]
—function-specific hazmat training covers the employees specific job functions as they relate to hazardous materials—such as classifying or naming materials; selecting authorized hazmat packaging; packaging shipments; marking, labeling, handling, loading, and unloading shipments; or completing hazmat shipping papers. Watch the video for a more in depth look at hazmat training requirements at 49 CFR 172.704—including additional requirements for safety training and security plan training.
2. Failure to provide recurrent hazmat training
The hazmat training described above must be repeated once every three years for each hazmat employee (49 CFR 172.704(c))
. This may seem simple enough, but keeping track of who needs refresher hazmat training—and when—can become complicated by staff turnover, new materials entering the facility, and other factors.
We’ll talk about training records below, but this is one area where keeping accurate, complete training records can help managers stay up-to-date on who on site needs hazmat training.
3. Failure to provide in-depth security plan training
In addition to the three hazmat training elements mentioned above, some facilities must train employees on their DOT hazmat security plan. A security plan is required for shipping facilities that offer certain amounts of specific, high-hazard materials for transport—explosives, compressed gases, poisonous-by-inhalation materials, bulk quantities of Class 3 flammables in PG I or II, organic peroxides, and others. The full list of materials that require a DOT hazmat security plan can be found at 49 CFR 172.800.
Security-plan training violations come in two varieties: a
. A hazmat security plan is in place, but employees were not trained on it; and b.
A hazmat security plan is required but has not been created
When a DOT hazmat security plan is
required—employees must be trained on the contents of the plan and, if applicable, their responsibilities under that plan. Even if it’s just “proceed calmly to the exit”-- employees have to know what to do in the event that the security plan must be executed.
4. Failure to keep adequate training records
Of all the hazmat training violations discussed, recordkeeping violations are the most common—and the easiest to avoid. Once all required elements of hazmat training have been covered, the employer must create a record of training for each employee. That record must contain specific items laid out in 49 CFR 172.704(d)
· Hazmat employees name;
- Most recent training completion date;
- Description, copy, or location of the training materials used;
- Name and address of training provider; and
- Employer certification that the employee has been trained and tested.
Avoid the #1 Most Common Violation
DOT Hazmat Training—Anytime, Anywhere
Be confident your shipping personnel know their responsivities for keeping dangerous goods shipments safe and in compliance. At Lion.com, find hazmat training options to help managers, warehouse staff, pickers, packers, administrative employees, and other master the DOT hazmat rules.
The final DOT Hazmat Ground Shipper Certification Workshops
of 2017 are coming to Cleveland, Pittsburgh, St. Louis, and Chicago this winter. Satisfy DOT training requirements and build the expertise needed to ship hazmat in full compliance with 49 CFR requirements—every time. A variety of hazmat online training is also available to help you train employees without the travel or lodging expenses.
Employees who know their responsibilities work more efficiently, and can ensure your shipments reach their destinations safely and on-time.