US DOT and OSHA both require training for employees who handle hazardous chemicals. Does this mean that employers must train each worker twice–once to satisfy DOT's safety training rule and once to satisfy OSHA's?
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.
Who Needs DOT Safety Training?
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.
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 Shipments
Safety 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
Emergency response information;
Protection measures to protect from exposure; and
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.
Emergency Response Information
You 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.
Because much of this information is found on a complete Safety Data Sheet or SDS, required under OSHA's Hazard Communication Standard (HCS), many employers choose to use the SDS to relay this information to personnel as part of a employee safety training (29 CFR 1910.1200
Workplace Exposure & Methods and Procedures to Prevent Accidents
Training 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 Packages
Hazmat 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 Program
When 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.