Who should be trained: Each “hazmat employer” is required to train each of his or her “hazmat employees” at least every 3 years. A hazmat employee is anyone who, in the course of employment, directly affects hazardous materials transportation safety. A brief list of employees who are likely to fit the definition of 49 CFR 172 definition includes anyone who:
Classifies materials (analyzes or researches literature);
Determines if a material is a hazardous waste or hazardous substance (determines RQs);
Assigns packing groups or hazard zones; Is involved in selecting shipping descriptions;
Designs, selects, purchases, or fills packages;
Determines if a package can be reused, if a package is empty, or if a package needs reconditioning (e.g., tank cars, cargo tanks, and drums);
Determines any markings or labels to be applied to a package;
Determines if placards are required, provides placards, or affixes placards;
Determines what should appear on shipping papers or actually fills out shipping papers;
Determines emergency response information to be included with shipping papers;
Selects carriers or modes of transportation to be used;
Loads, unloads, moves, handles, or works around hazardous materials (e.g., warehouses or loading docks);
Responds to damaged containers, spills, or leaks and reports incidents; and
Operates any vehicle or equipment used to transport hazardous materials.
Anyone who directly supervises those performing any of the above activities also needs to be trained. In addition, hazmat employers must also assure that anyone performing any regulated function on their behalf, such as a contractor, has been fully trained before they begin their work.
US DOT Hazardous Materials Regulations (HMR) requires companies to compliy and include but not limited to:
Offer hazardous materials for transportation;
Package, mark, or label hazardous materials for transportation;
Load or unload hazardous materials transport vehicles;
Transport hazardous materials;
Receive and forward packages containing hazardous materials;
Manufacture packaging for use in transporting hazardous materials; and
Test hazardous material packaging.
The DOT Hazardous Materials Transportation Training is based on 49 CFR 172; subpart H requires certain categories of training.
At a minimum, all hazmat employees must be given a general understanding of the entire hazardous materials transportation program, so that they know how their jobs fit into the system.
All hazmat employees must also be trained on any specific job functions that they perform in relation to the hazardous materials regulations.
Persons handling or potentially exposed to hazardous materials during the cycle of transportation (e.g., drivers, loaders, loading dock workers, and warehousemen) must be trained in safe handling and emergency response procedures applicable to the hazards to which they may be exposed.
All hazmat employees must be trained to recognize and protect against potential terrorist threats involving hazardous material shipments. NOTE: High risk shipments required additional training.