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How Much Hazmat Training is Enough?

Posted on 10/12/2020 by Lion Technology Inc.

The regulations for handling and shipping hazardous materials are complex. Even when you have a strong handle on the domestic and international requirements that impact your shipments, you may still feel uncertain that you have dotted every “i” and crossed every “t.” 

When it comes to hazmat training, you want to feel confident that every employee has the training he or she needs to thrive in a hazmat job role. To build an effective, lasting hazmat training program in your organization, you first need a clear idea of how each employee will impact hazmat transportation safety, and what kind of training the US Department of Transportation (DOT) requires for that job role.

US DOT’s hazmat training rules, found at 49 CFR Part 172, Subpart H, have a four-fold purpose.

When training is complete, each hazmat employee should:
  1. Have familiarity with the general provisions of the hazmat rules;

  2. Be able to recognize and identify hazardous materials;

  3. Have knowledge of specific requirements of the hazmat rules applicable to the functions performed by the employees; and

  4. Have knowledge of emergency response information, self-protection measures and accident prevention measures.

Training All Hazmat Employees

Who is subject to this training mandate? All hazmat employees must receive training. A hazmat employee is anyone who directly affects the safe transportation of hazardous materials and includes full-time, part-time, and contract employees (Read more: Hazmat Training FAQ). 

Employers must provide hazmat training within 90 days of a new employee's hire date or a change in job function (49 CFR 172.704(c)(1)(ii)). In addition, employees must work under direct supervision until hazmat training is complete. 

Hazmat training is not a one-size-fits-all operation. Each hazmat employee needs training that covers his or her responsibilities for hazardous materials transportation safety. Decision-makers who classify and name materials or sign shipping papers require much more in-depth hazmat training than an employee that simply drives a forklift to load hazmat onto a vehicle.

Read more: Hazmat Training FAQ 

Training Required for All Hazmat Employees

All hazmat employees must have:
  • General awareness/familiarization training provides familiarity with the requirements of the 49 CFR hazmat regulations and prepares employees to recognize and identify hazardous materials.

  • Security awareness training: to acquire an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security.

  • Function-specific training concerns requirements of this subchapter, or exemptions or special permits, that are specifically applicable to the functions the employee performs.

Typical hazmat job functions include (but are not limited to):
  • Hazard classification including gathering information (e.g. analysis, SDSs, industry info), assessing data and assigning hazard classes/divisions and subclassifications;
  • Choosing a proper shipping name from the 49 CFR 172.101 table using the DOT’s order of specificity and other standards;
  • Purchasing packaging authorized for a material and understanding UN specification markings;
  • Assembling, filling and closing packaging according to the manufacturer’s written instructions;
  • Marking and labeling a package;
  • Filling out and signing shipping papers;
  • Offering placards to a truck driver or displaying them on rail cars;
  • Loading or unloading hazardous material from freight or cargo tank trucks;
  • Following special permit requirements or exemptions (e.g. the materials of trade exemption) appropriately; and
  • Adhering to applicable administration requirements like registration and incident reporting.
How much training and which subjects an employee must learn depends on the employee’s individual responsibilities.

Hazmat Training to Sign Shipping Papers

An employee who signs a shipping paper certifies that the hazmat is properly classified, named, packaged, marked and labeled/placarded properly, so that employee must be fully trained in all of those subjects.

An employee who loads hazmat into a vehicle must be familiar with hazmat separation and segregation rules and how to secure hazmat packages on a motor vehicle. This employee must also know the safety requirements for the motor vehicle, like setting the truck’s handbrake and other methods used to keep the vehicle from moving at the wrong time.

Hazmat Safety and Security Plan Training

Two other types of hazmat training are required for some hazmat employees.  

In-depth security training required by 49 CFR 172.704 covers the elements of your site’s written security plan – if you have one! [See 49 CFR 172.800(b) for applicability];
 
Hazmat safety training prepare employees to review emergency response information, protect him or herself from harm, and implement methods to avoid accidents and exposure. Hazmat safety training may be covered under your organization’s OSHA training program. Read more: What is Hazmat Safety Training and Who Needs It?

Re-training and Update Training

US DOT requires each hazmat employee to complete recurrent training once every three years (49 CFR 172.704(c)(2). 

Hazardous materials regulations are not static; they change all the time. When regulations change that impact an employee's hazmat job function–for example, if a new packaging type or marking must be used for your material–the employee's training must be updated accordingly. 

Initial and Recurrent DOT Hazmat Training–Live! 

Join a full-time Lion instructor for live, expert-led hazmat webinars to help meet DOT's initial or recurrent training mandates. 

The training provided at our two-day DOT workshops is available in a live webinar format for Fall/Winter 2020. Sign up, sign in, and get the training you need to keep your shipments in compliance with the latest 49 CFR hazmat shipping requirements.  

Hazmat Ground Shipper Certification (2 Days) 
October 20–21   November 18–19   December 16–17

Recurrent Hazmat Ground Shipper Certification (1 Day) 
November 5   December 3
 

Tags: 49 CFR, 49 CFR 172.704, hazmat training, shipping hazmat

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