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Hazmat and RCRA Testing Requirements for Training

Posted on 3/31/2015 by Scott Dunsmore

When planning your team's hazmat shipping or RCRA hazardous waste training, one important element to consider is testing. Is a test required to meet the training standard? If so, what kind of test must students complete and how should it be administered? As is often the case with regulatory questions, the answer is: "It depends."

49 CFR Hazmat Employee Training

The US DOT requires all hazmat employees to complete training once every three years. As part of its hazmat training mandate, found at 49 CFR 172, Subpart H, DOT requires the hazmat employer to ensure that all hazmat employees are "tested by the appropriate means on the training subjects covered." [49 CFR 172.702(d), emphasis added] Whether hazmat training is presented by in-house personnel or delivered by a full-time training provider, the employer must ensure that the training includes some effective and "appropriate" means for testing.


Determining Appropriate Hazmat Testing

So, what is an "appropriate" means for testing in a hazmat training class? DOT's hazmat employee training standard includes a requirement for "function-specific" training. [49 CFR 172.704(a)(2)] Because each employee must be trained on the specific elements of his or her hazmat job, the appropriate test method may vary. Depending on the responsibilities of the hazmat employees who are completing training, the appropriate way to test could be a written (i.e., objective or subjective), oral, or practical test.

For a group of compliance managers, for example, "function-specific" training would include guidance on navigating the text of the regulations, classifying materials, and making other complex determinations. For this training, a written test may be the best evaluation method. The test may comprise multiple choice or case-scenario testing to make sure hazmat managers have the skills they need to oversee operations.

Hazmat RCRA Test
If the target audience is a group of warehouse hazmat employees who fulfill orders, pack materials, and affix hazmat marks and labels, a practical or hands-on test may be the most appropriate means of evaluating their skills.

Following classroom-style training, the test may consist of handing the hazmat employees an order and instructing them to select the appropriate packaging from an assortment; properly assemble, fill and close the package; and then select and affix the necessary marks and labels. The instructor can observe the students and evaluate their success against the course's learning objectives.

The same logic could be applied in determining the appropriate means for testing the other hazmat employee training elements at 49 CFR 172.704 (i.e., general awareness, security awareness, safety, and security plan).

RCRA Hazardous Waste Personnel

Unlike the training requirement for hazmat employees, US EPA's annual training mandate for hazardous waste personnel (40 CFR 264.46 and 265.16) does not have a stated testing requirement. EPA's RCRA training standard requires employers to provide personnel with job-specific instruction, and EPA expects that the training content be designed to instruct personnel in their duties consistent with the regulations.

While testing is not explicitly required by EPA's RCRA hazardous waste rules, evaluation is a critical component to any effective training program. Training, in general, is supposed to transfer the necessary skills to the audience so that they can perform their tasks to a stated standard. Like testing for hazmat employees, choosing an appropriate testing method for hazardous waste personnel will depend on the target audience and the RCRA hazardous waste training topics covered.

Evaluation and feedback are each critical components of training design. Whether or not the training standard requires testing for your employees, a test can be the most effective, efficient way for an employee to demonstrate the skills or knowledge he or she learned through training. When deciding which testing method may be appropriate, managers responsible for developing employee training should take into account the specific skills covered by the training, the company's desired outcomes, and how the target audience will use what they've learned.


Expert RCRA and Hazmat Shipper Training

There is no such thing as "one-size-fits-all" training. Employee training and testing will vary depending on the employees' responsibilities; the materials they handle, store, or ship; job experience, and other factors. Lion Technology offers training that spans the gamut of possibilities.

Lion offers management-level workshops and online courses for hazmat shipping and logistics managers, RCRA program managers, EHS managers, and other corporate leaders. For hands-on personnel who do not manage other employees or make critical regulatory decisions, job-specific online training is available.

Tags: hazmat training, RCRA Training

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