What is Hazmat Safety Training and Who Needs It?
No, it doesn't. In fact, the Hazardous Materials Regulations (HMR) explicitly state that training provided under other regulatory programs (like OSHA safety training) may be used to comply with the DOT’s safety requirements (see 49 CFR 172.704(b)).
For hazmat shippers, US DOT's 49 CFR regulations require hazmat training to cover five distinct topics defined in 49 CFR 172.704: General Awareness, Function-specific, Security Awareness, Security Plan, and Safety Training. Safety training is one area where OSHA provides helpful details about what training should include.
Lion offers easy-to-use online hazmat training for personnel who package, mark, label, load, unload, and handle hazardous materials ground, air, and vessel shipments.
At Lion Technology hazmat training seminars, we often discuss how only some hazmat employees need DOT safety training. That is because while DOT requires training for all employees who “directly affect” hazardous materials transportation safety, not every employee who affects transportation safety runs a risk of exposure to hazardous materials.
Who Needs DOT Safety Training?
US DOT’s official policy is that “Safety Training” is for hazmat employees who physically handle or transport hazmat packages and who may be exposed to hazmat as a result of a transportation accident. This is understood to include packers, warehouse personnel, drivers, train crews, and employees who load/unload aircraft and vessels. [57 FR 20949, May 15, 1992]
Some regulated hazmat jobs (i.e. “functions”) can be done off-site, without ever coming near a hazardous material. Choosing or ordering the proper packaging for use at various remote shipping sites, for example. If the employee responsible for ordering hazmat packaging would never actually come into direct contact with the materials being shipped, the employer is not required to provide hazmat safety training.
That said, an employee who orders hazmat packaging from an off-site office still needs hazmat training commensurate with his or her responsibilities, just not safety training. These employees would still need training to properly perform their hazmat function—i.e. to identify and use relevant information about the material to select an appropriate packaging. Hazmat General Awareness and Security Awareness training would still be required, as well as function-specific training needed to select the proper package.
Safety Training for Workers Handling ShipmentsSafety training is required for workers who physically handle hazardous materials. DOT lists three specific topics that must be included in safety training for these workers.
According to 49 CFR 172.704 (a)(3), each hazmat employee shall receive safety training concerning:
(i) Emergency response information;
(ii) Protection measures to protect from exposure; and
(iii) Avoiding accidents/handling packages.
To determine what exactly should be covered by this training, it can help to consider the OSHA employee safety regulations. OSHA provides detailed minimum training requirements for several different categories of employees in the workplace. Many of these have recurrent training requirements, minimum number of training hours, and testing requirements; though they vary a great deal based on the specific job duties.
Find OSHA Hazard Communication training in English and Spanish to inform and protect employees who handle and package hazardous chemicals in you workplace.
Emergency Response InformationYou must train your hazmat employees on the hazard communication information that must be sent with each hazardous materials/dangerous goods shipment based on subpart G of part 172.
DOT requries these 7 pieces of information:
- The basic description and technical name of the hazardous material
- Immediate hazards to health;
- Risks of fire or explosion;
- Immediate precautions to be taken in the event of an accident or incident;
- Immediate methods for handling fires;
- Initial methods for handling spills or leaks in the absence of fire; and
- Preliminary first aid measures.
Workplace Exposure & Methods and Procedures to Prevent AccidentsTraining workers to avoid and respond to workplace exposure is another area where OSHA provides more fleshed-out training requirements than US DOT. Workers should be trained to properly select and use personal protective equipment when needed, for example.
There are also elements of employee safety that are specific to your facility. Employees should not only know that gloves are needed to handle a material, but also where to find gloves or other PPE when needed. If an employee needs to use an eye-wash station or shower after a chemical exposure, he or she should know where that equipment is located in your facility, and how to operate it properly.
Avoiding Accidents and Handling PackagesHazmat employees must also be trained to use safe work practices while packaging, handling, or loading hazardous materials. This can include training employees to recognize chemical labels, use safe lifting and handling practices, and understand the risks posed by the materials in your workplace.
Employers often use OSHA Hazard Communication or HazCom training to satisfy some of these requirements, again because OSHA provides much more detailed instructions for what safety training should include.
How to Implement A Comprehensive Safety Training ProgramWhen creating a consolidated training program, it is crucial that you meet all the minimum requirements for each agency training requirement you are hoping to cover. While safety programs often overlap, it is critical to document all of the training that you provide in employee training records. If OSHA HazCom or 10 Hour training is used to satisfy DOT's safety training requirement, for example, this must be recorded as part of the employee training record required by 49 CFR 172.704(d).
Employee hazmat training records are an easy target for hazmat inspectors, who will expect to see complete records of all training performed to ensure compliance with the HMR.
Lion’s DOT Hazmat training makes it easy for you, your co-workers, and your entire shipping staff to get the training you need. Click here to see our full schedule of in-person workshops coming to Philadelphia, Atlanta, Houston, San Francisco, and more.
Tags: hazardous materials safety, hazmat training, osha, PHMSA, safety training
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This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.
The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.
Hazmat Shipping Professional
Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.
Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training.
The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.
Hazmat Shipping Professional
I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!
Senior Environmental Engineer
Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.
Chemical Laboratory Manager
Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.
Environmental, Health & Safety Regional Manager
Lion courses are the standard to which all other workshops should strive for!
Registered Environmental Health Specialist
The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry.
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