Who Needs DOT Hazmat Safety Training?

For every employee who directly affects hazmat transportation safety, the US DOT's 49 CFR Hazardous Materials Regulations (HMR) requires hazmat training to cover five distinct topics defined in 49 CFR 172.704. One of those five topics is safety training, but not every employee who directly affects hazmat transportation needs it, according to the US DOT.

To ensure compliance with the US DOT’s training requirements, you need to know:

• Who is required to complete DOT safety training.
• What safety training must cover.
• How to implement and keep records for a comprehensive safety training program.

Who Is Required to Complete DOT Safety Training?

Not every employee who affects transportation safety runs a risk of exposure to hazardous materials. 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. One example is choosing or ordering the proper packaging for use at various remote shipping sites. 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 to this individual.

What Must DOT Safety Training Cover?

The DOT lists three specific topics that must be included in safety training for workers who physically handle hazardous materials. According to 49 CFR 172.704(a)(3), each hazmat employee shall receive safety training covering:

• Emergency response information.
• Measures to protect from exposure.
• Methods for avoiding accidents when handling packages.

While determining the exact topics to include in safety training, it can be helpful to also consider 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 greatly based on specific job duties.

Emergency Response Information

Additionally, hazmat employers must train their hazmat employees on the emergency response information that must be sent with each hazardous materials/dangerous goods shipment, as required by 49 CFR 172, Subpart G.

The US DOT requires seven pieces of information:

1. The basic description and technical name of the hazardous material.
2. Immediate hazards to health.
3. Risks of fire or explosion.
4. Immediate precautions to be taken in the event of an accident or incident.
5. Immediate methods for handling fires.
6. Initial methods for handling spills or leaks in the absence of fire.
7. Preliminary first-aid measures.

Much of this information is found on a hazardous material’s Safety Data Sheet, or SDS. Because using an SDS is required under OSHA's Hazard Communication Standard (HCS), many employers choose to use this document to relay most of the emergency response information to personnel as part of their safety training (29 CFR 1910.1200). Before doing so, employers must be sure to double-check any SDS they are referencing for safety information.

Measures to Prevent Exposure

Training workers to avoid and respond to workplace exposure is another area in which OSHA provides more fleshed-out training requirements than the US DOT. For example, OSHA requires workers to be trained to properly select and use personal protective equipment when needed, while the DOT does not touch on this topic.

Employers have to keep in mind that there are elements of employee safety that are specific to each facility. For instance, employees should not only know that gloves are needed to handle a material, but also where to find those gloves or other PPE, when needed. If employees need to use an eye-wash station or shower after a chemical exposure, they should know where that equipment is located and how to operate it properly.

Avoiding Accidents and Handling Packages

Hazmat employees must also be trained to use safe work practices while packaging, handling, or loading hazardous materials. This can be done by teaching employees how to recognize chemical labels, use safe lifting and handling practices, and understand the risks posed by the materials they encounter in the workplace.

This is another area where employers often use OSHA’s Hazard Communication, or HazCom, training, again because this Agency provides much more detailed instructions for what safety training should include.

Implementing and Recordkeeping for a Comprehensive Safety Training Program

When creating a consolidated training program, it is crucial that employers meet all the minimum requirements for each Agency’s training requirement they are hoping to cover. While safety programs often overlap, it is critical to document all the provided training in employee training records. If OSHA HazCom or 10-hour training is used to satisfy the 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.

To help satisfy US DOT’s safety training requirements, browse Lion’s HazCom safety training courses at Lion.com/HazCom. To help satisfy US DOT’s general awareness, function-specific, and security awareness training mandate for hazmat employees, sign up for Lion’s Hazmat Ground Shipper Certification online course, live webinar, or in-person public workshop.

Tags: hazmat, hazmat safety, hazmat shipping, safety training