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What Lion Instructors Won't Tell You

Posted on 7/1/2021 by Roseanne Bottone

If you’ve attended training about hazardous materials, environmental protection, workplace safety, or some other area of regulatory compliance, you have probably heard a question answered this way at least once.

“Trust me—that’s what the regulations say.”

You won't hear experienced trainers say "trust me" very often, and you won’t hear questions answered this way in a Lion classroom. 

Here why: The answer "trust me" implies that the student should follow instructions without understanding the nuances of a rule, its intent, or how it was developed. If a trainer encourages a student to do things a certain way Just Because, the student won’t develop the skills needed to work through a compliance challenge individually.

The regulations are chock-full of gray areas and not every situation can be handled neatly or exactly by-the-book. Knowing what the regulations say does not ensure success. The text of hazardous materials, environmental, and safety regulations are dense, complex, self-referential, and, at times, written in confusing government language.

To succeed in your role as an EH&S professional, you need the knowledge and skills to navigate, interpret, and apply regulations to real world situations—not just the ability to read them.

In the classroom and online, Lion instructors strive to educate, entertain, and empower industry professionals. We don’t answer questions with “Trust me.” Instead, we design and deliver training that helps professionals develop knowledge and skills to solve compliance challenges independently.

So how do Lion instructors answer difficult questions in our upcoming hazmat and RCRA workshops? You've got to be there to find out! In the meantime, read on to see 5 ways Lion instructors give meaningful answers to difficult compliance questions during workshops. 
 

Upcoming workshops: 
Hazmat Shipper Workshops (DOT, IATA, IMDG)
RCRA Hazardous Waste Management 
California Hazardous Waste Management 
Texas Hazardous & Industrial Waste Management 
 

5 Ways Lion Answers Challenging Questions

"That subject is found in [Title, Part, Section, Paragraph]. Let’s take a look at the exact wording used in the regulations." 
Regulations can be like an ink blot test. Two people might read the same words, in the same order, but come away with wildly different interpretations. Let’s read the text of the regulation, dissect it together, and determine how it applies to a specific activity.

"Your Compliance Reference includes an exhibit that covers this issue. Let’s open it to page…"
Course resources included with Hazmat Ground Shipper Certification workshopWhen you attend a Lion workshop, you receive unrivaled, practical resources and reference materials.  On almost every page you will find regulatory references and source notes you can follow to get more info straight from the source.

When you want to verify specific language or take a deeper dive—your Lion resources make it easy to find what you’re looking for.
 
Pictured: Course resources included with Lion's upcoming two-day Hazmat Ground Shipper Certification (DOT) Workshop

"The [DOT/EPA/OSHA] answered a similar question in a Letter of Interpretation or guidance document. We can find you a copy of that."
Because the text of the regulations can sometimes be unclear, regulated persons and industry groups contact agencies like US DOT, EPA, and OSHA regularly to ask for clarification.

The letters of interpretation that agencies write in response to these questions can provide insight into their thought process. That said, each letters applies only to the individual facility and the specific situation it addresses. They are not legally binding and do not supersede the regulations.

Our goal is to empower you and we will be happy to track down a guidance document or letter of interpretation that will help you strengthen your understanding. 
 
"The preambles in the Federal Register (FR) can help explain [DOT/EPA/OSHA]'s intent and choice of wording. Your Compliance Reference also include FR citations." 
When an agency promulgates a new regulation, the Final Rule text typically includes explanations of the Rule’s purpose, the agency’s intent, and how they plan to implement it. The preamble to the rule will also address public comments the agency received during the rulemaking process, and provide other useful information that can help you understand how the rulemaking will impact your facility.

Citations and source notes throughout Lion’s unmatched course manuals will make it easy for you to research compliance topics in a targeted, informed way.
 
"I’m not sure. Can you give me a chance to look that up/investigate and get back to you?" 
Lion instructors are only human! While we may seem like walking encyclopedias of regulatory knowledge sometimes, we can’t possibly memorize every word of the regulations.

Now and then at a workshop, a student voices a question or circumstance we've never encountered before. We love when this happens. It gives us a chance to provide you with the right answer through research and gives us an opportunity to learn something new. 

Included: Ongoing Compliance Answers & Support

At Lion, we know the challenge of regulatory compliance doesn’t end when training is finished—it’s just beginning. When you attend a Lion workshop, you get a full year of Lion Membership for ongoing regulatory support, including the Finder Q&A Service.

Submit compliance questions through Lion.com/Finder and get reliable, thoughtful response from Lion instructors and subject matter experts. You will receive a response within 2 business days (usually sooner) that directs you to the regulatory references, letters or interpretation, and other available resources that back up our answer.   

Lion Members also get access to exclusive resources at Lion.com/Members, including a monthly regulatory summary, Bulletins about new and changing regulations, a New Rules section to keep up with relevant Federal Register releases, and much more. Current Members can view the recently re-designed Member Area here.

Learn more about Lion Membership.

Lion Hazmat & RCRA Workshops Are Back for 2021!

Get answers to your site’s compliance questions when Lion workshops return to a city near you.

DOT Hazmat Ground Shipper Certification Workshop

Develop a step-by-step process to prepare and offer hazardous material shipments by highway in full compliance with US DOT’s Hazardous Materials Regulations (HMR). This two-day workshop will help satisfy DOT PHMSA’s hazmat training mandate for hazmat employees, found at 49 CFR 172.704.
 
Charlotte, NC Aug. 10–11
Orlando, FL Aug. 16–17
Nashville, TN Aug. 24–25
Atlanta, GA Aug. 30–31
Houston, TX Sep. 14–15
Dallas, TX Sep. 20–21
San Diego Sep. 28–29

Expand on your 49 CFR expertise. For air and vessel shippers, Lion also presents in-person IATA DGR and IMDG Code workshops: Hazmat Air Shipper Certification (IATA) | Hazmat Vessel Shipper Certification (IMDG)

RCRA Hazardous Waste Management Workshop

Build in-depth expertise to identify, store, and dispose of your site’s hazardous waste in full compliance with RCRA—from cradle-to-grave.
 
Houston, TX* Aug. 18–20
Dallas, TX* Aug. 23–25
Chicago, IL Sep. 13–14
St. Louis, MO Sep. 16–17
Pittsburgh, PA Sep. 20–21
Cincinnati, OH Sep. 23–24

*Presented with the Texas Haz & Industrial Waste Management Workshop on Day 3

Tags: hazmat training, RCRA Training, workshops

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