Can New Hazmat Employees Work Before They’re Trained?
In the real world, a shipping department can’t stop and wait for a new employee to finish in-depth training. Clients are waiting for deliveries and product must move out the door at an increasingly rapid pace. In addition to their responsibilities for hazardous materials safety, hazmat shippers deal with the same pressures that impact logistics professionals of all stripes—pressure to be more efficient, to cut costs, to improve ROI, and so on.
Need to train a new hazmat employee? The Shipping Hazmat by Ground—Ops online course will prepare pickers, packers, material handlers, warehouse workers, and administrative staff to identify and meet their responsibilities under the 49 CFR Hazardous Materials Regulations. Training for air and vessel shipping employees is also available.
So, can a new hazmat employee perform shipping jobs with hazardous materials before he or she completes required hazmat training?
The answer—and this may surprise some shippers—is yes.
Per 49 CFR 172.704 (c)(1)(i), new hazmat employees may perform hazmat job functions before they’ve been trained, provided that the new employee:
A Closer Look: Hazmat Employee Training Requirements
- Is directly supervised by a properly trained and knowledgeable hazmat employee; and
- Completes hazmat training within 90 days after being hired or changing jobs.
“Directly supervised” means that the supervisor has a direct line-of-sight to the new hire and can guide him or her at all times the employee is performing any regulated hazmat function—from classification of hazardous materials to packaging, marking, labeling, loading, unloading, and handling shipments.
What Does “Directly supervised” Mean?
Anecdotally, we’ve heard of a shipper who provided step-by-step packaging directions to hazmat employees by phone before they’d completed their hazmat training. This is NOT “direct supervision” in PHMSA’s eyes.
Neither is “supervising” an employee from a closed office down the hall.
Further reading: 4 Avoidable Hazmat Training Violations
When a new hazmat employee does complete training, that hazmat training must cover the following topics:
Hazmat Training for New Employees
General awareness training
Security awareness training
Security Plan Training
If your site is required to maintain a security plan per 49 CFR, then all employees with responsibilities under that plan—including the “responsibility” of evacuating—should be trained on the plan and how it will be used in an emergency.
New hazmat employees need a solid grasp of the hazmat regulations and what they must do to help maintain compliance. Every step of the hazmat shipping process is regulated in some way, and even small mistakes can lead to fines now approaching $80,000 per day, per violation.
Hazmat Training for New and Experienced Hazmat Employees
The Shipping Hazmat by Ground—Ops Online Course provides hazmat general awareness, security awareness, and function-specific training for new or experienced hazmat employees. Personnel who complete this course learn the keys to hazmat compliance, and how to comply with the regulations that govern each type of hazmat job.
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