Hazmat Employer’s Duty—Ensure Your Employees’ Training

Posted on 3/23/2020 by Lauren Scott

The 49 CFR explicitly states that “hazmat employers” must ensure their “hazmat employees” are training to perform their essential job functions [49 CFR 172.702(a)]. But who exactly needs training and what kind of training is required? We answer these questions and more.

What’s a Hazmat Employer?

DOT defines a “hazmat employer” as any entity that
  • Transports hazardous materials in commerce;
  • Causes hazardous materials to be transported in commerce; or
  • Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package, container, or packaging component that is represented, marked, certified, or sold by that person as qualified for use in transporting hazardous materials in commerce.
Such entities could be either a person who employs at least one hazmat employee; self-employed; or a State, Federal, or Tribal agency or political subdivision. [49 CFR 171.8]

Who Must Be Trained?

Anyone who directly affects the safety of transportation of hazardous material must be trained. The term “hazmat employee” includes anyone who is self-employed as well as persons employed full-time, part-time, or on a temporary basis that affects hazardous materials transportation safety, including railroad signalmen and maintenance-of-way employees.
Such individuals may perform at least one of these duties during the course employment:
  • Load, unload, or handle hazardous materials;
  • Design, manufacture, fabricate, inspect, mark, maintain, recondition, repair, or test a package, container, packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.
  • Prepare hazardous materials for transportation;
  • Manage the safety of transporting hazardous materials; or
  • Operate a vehicle used to transport hazardous materials. [49 CFR 171.8]
49 CFR gets even more specific about who needs hazmat training. At 49 CFR 171.1(b), you can find a list of regulated “pre-transportation functions.” Any employee who performs these jobs must have appropriate training.
These functions include:
  • Determining a material’s hazard class
  • Selecting, filling, and/or closing a hazardous materials packaging;
  • Marking or labeling a package to indicate that it contains a hazardous material;
  • Preparing or reviewing a shipping paper;
  • Loading, blocking, and bracing a hazardous materials package in a freight container or transport vehicle; and
  • Selecting, providing, or affixing placards for a freight container or transport vehicle to indicate that it contains a hazardous material.
  • Providing or maintaining emergency response information
  • Reviewing shipping paperwork to verify compliance

What Training is Required?

All hazmat employees must be trained for general awareness, function-specific procedures, and security awareness. Additionally, some hazmat employees may need training in safety or cargo security plan specifics.

Training given under other training requirements (such as OSHA hazard communication/HazCom or HAZWOPER training) may be used toward satisfying DOT’s training requirement, but it must be documented in accordance with DOT rules. For example, a person who had OSHA training would not need safety training under DOT.

Is Hazmat Training Required to Sign Hazardous Waste Manifests?

Yes! Included within the definition of hazardous materials are hazardous wastes. The DOT defines a hazardous waste as “any material that is subject to the Hazardous Waste Manifest Requirements of the US Environmental Protection Agency specified in 40 CFR part 262.”

Therefore, a RCRA hazardous waste requiring the use of a manifest is regulated as a DOT hazardous material.
According to DOT, “…[E]ach person who offers a hazardous material for transportation shall describe the hazardous material on the shipping paper in the manner required by this subpart,” [49 CFR 172.200].

When Must Training Be Done?

Initial training must be completed prior to performing a job function or with 90 days for new hires working under direct supervision of someone who is properly trained and knowledgeable. This supervisor must be able to notice and correct any mistakes. Merely reporting to a trained employee does not satisfy this requirement. [49 CFR 172.704(c)(1)]

Additionally, hazmat employees must be retrained no more than three years from the anniversary date of initial training. [49 CFR 172.704(c)(2)] Employers must ensure testing and create an updated record of training. [49 CFR 172.704(d)]

Online Hazmat Shipper Training When and Where You Need it

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Lion has online hazmat training to cover the latest 49 CFR (US DOT), IATA DGR, and IMDG Code regulations that govern the domestic and international transport of hazardous materials. 
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Tags: 49 CFR, DOT, DOT training, haz mat, haz mat training, hazardous materials, hazardous materials training, hazmat, hazmat training, ship hazmat

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