The U.S. Department of Transportation (DOT) requires that all “hazmat employees” receive training to perform their jobs correctly and ensure compliance with the Hazardous Materials Regulations. [49 CFR 173.1(b)] In general, a hazmat employee is anyone who in the course of his or her employment directly affects the safety of transportation of hazardous materials.
Hazmat employee training must include, at minimum, general awareness, security awareness, and function-specific training. [49 CFR 172.704(a)] The term “function-specific” training refers to training on the rules that apply to a hazmat employee’s particular job duties.
Many everyday job duties of hazmat shippers or carriers can directly affect the safety of hazmat transportation, and personnel who perform these jobs must complete training. Below are a few examples of common job functions covered under this DOT training requirement.
Classifying Hazardous Material
It is the shipper’s responsibility to ensure that the hazmat being offered for transportation is properly classified and assigned the most accurate and specific Proper Shipping Name available. When material is not properly classified, it may be mishandled before and during transport.
Employees who classify hazmat and assign shipping names must be familiar with the physical, chemical, and/or toxicological attributes of the material and the criteria in 49 CFR Parts 172 and 173.
Selecting, Filling, and Securing Hazmat Packages
Part 173 of the Hazardous Material Regulations (HMR) includes general requirements and prohibitions for packaging hazmat, such as ensuring that the packaging was designed, constructed, and maintained to appropriate performance standards and is compatible with the hazmat it will contain. In addition to these general standards, Part 173 authorizes only certain types of packagings and prohibits others for each hazardous material. After selecting an appropriate packaging, the shipper must fill it with hazmat and secure it closed following the manufacturer’s instructions.
Hazmat employees who will select, fill, and secure hazmat in packagings must be trained on how to perform these functions to prevent rejected shipments and incidents in transit.
Marking, Labeling, and Placarding
During transport, packages and/or consignments of hazardous materials must display marks, labels, and sometimes placards in order to communicate the presence of hazmat to transport workers and emergency responders so that the packages can be managed properly.
Affixing these marks, labels, and placards is generally performed before the packages are offered for transportation. Hazmat employees who prepare packages for transport must follow all applicable rules and regulations for these hazard communications and must be trained accordingly.
Loading and Unloading Hazmat from Transport Vehicles
The last pre-transportation function regulated by the HMR is loading the hazmat onto a motor vehicle or into a freight container. Instructions for safely loading hazmat and securing the load in the freight unit are found in 49 CFR Parts 174–177, the transportation rules for each mode of transport. When these functions are performed by shippers, they must comply with, and be trained on, these modal regulations. In certain cases, such as for cargo tanks, these regulations also cover unloading the material at its destination.
Effective training is critical for all hazmat employees, as a mistake during any step of the shipping process can begin a chain reaction. For example, the affixing of incorrect marks, labels, and/or placards can lead to mishandling and wrong emergency response actions by first responders. Employers must ensure that all hazmat employees are prepared to perform their jobs correctly to avoid incidents in transit, rejected shipments, and fines as high as $75,000 per day, per violation. Failure to provide employees with sufficient training is one of the most commonly cited violations of the HMR and the only violation for which a mandatory minimum penalty has been established.
Lion Technology presents convenient, effective online training for a number of the specific jobs listed above, including packagers, clerical assistants, loading dock workers, and more. Find a complete list of Lion’s online hazmat training options at www.Lion.com. Courses are available 24/7, and students can stop and start anytime to help fit training into your team’s schedule.