To achieve its goal of safe transportation of hazardous materials (HazMat), the Pipeline and Hazardous Materials Safety Administration (PHMSA) within the US DOT requires any person who performs a function involving the transportation of hazardous materials within the US to receive training on the safe and proper execution of those functions. It is you as the HazMat Employer who must certify that the training and testing – that’s right, testing is required – of your HazMat Employees is sufficient to comply with the regulations. With this responsibility to train, test, and certify the training of applicable employees, it is important for you to know what the regulations are and how you must comply with them.
First, you should review 49 CFR 172, Subpart H since it includes everything you need to know about the applicability, frequency, and content of HazMat Employee training. You may also review the training information available on thePHMSA website. There are the following five types of training that may be required:
- General Awareness Familiarization Training
- Function Specific Training
- Safety Training
- Security General Awareness Training
- In-Depth Security Training
General Awareness/Familiarization Training is required for all HazMat Employees. It must provide familiarity with the Hazardous Materials Regulations (HMR) and enable the HazMat Employee to identify a hazardous material using the hazard communication methods: shipping papers, placards, labeling, and marking.
Function Specific Training is required for all HazMat Employees. This training must instruct each HazMat Employee how to perform their specific job function(s) in compliance with the regulations. This may include: the completion and signing of shipping papers (including the Uniform Hazardous Waste Manifest), the loading or unloading of hazardous material packages from a vehicle, the transfer of bulk quantities of hazardous materials from a tank truck or railroad tank car, the preparation of hazardous material packages for shipment, and more. If applicable to your operations, training per the requirements of the International Civil Aviation or the International Maritime Organization for the shipment of Dangerous Goods may be provided in lieu of training on the requirements of the HMR.
Safety Training is required for all HazMat Employees. This training must address the potential hazards posed by the HazMat in use at the facility. It must also instruct the HazMat Employees in the ways they and their employer can provide protection from these hazards, the emergency response procedures of 49 CFR 172, Subpart G, and accident avoidance.
Security General Awareness has been required for all HazMat Employees since March 25, 2003. This training must include the following:
- Awareness of security risks associated with hazardous materials transportation.
- Awareness of methods to enhance transportation security.
- How to recognize and respond to possible security threats.
In-Depth Security Training is required only for applicable HazMat employees of companies that are required to have a DOT Security Plan. DOT Security Plan applicability can be determined at 49 CFR 172.800(b). Note that the conditions to determine applicability changed effective October 1, 2010; you can read more about that here. An applicable HazMat Employee – one who requires In-Depth Security Training – is one who: handles hazardous materials covered by the Plan, performs a regulated function related to the hazardous materials covered by the Plan, or is responsible for implementing the Plan. Training must include:
- Company security objectives.
- Organizational security structure.
- Specific security procedures.
- Specific security duties and responsibilities for each employee.
- Specific actions to be taken by each employee in the event of a security breach.
Training required by OSHA, EPA or other agencies may suffice to fulfill the DOT training requirements above. In other words, you don’t need to train your employees on the same material twice as long as the training addresses the specific components outlined above. Whatever you do, be sure to retain the required documentation to prove you conducted the necessary training and testing.
The purpose of training is to increase awareness of safety and regulatory requirements. It is hoped that the resulting awareness leads to fewer HazMat transportation incidents and related injuries/fatalities. Effective training can do much more than meet the regulatory requirements however, it can provide your HazMat Employees with the information and the tools they need to perform their job functions safely and more efficiently. Don’t take my word for it, read on the PHMSA website about its PHMSA Training Requirements.