training requirements for hazmat employees

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HAZMAT EMPLOYEE TRAINING REQUIREMENTSPursuant to the US DOT regulations at 49 CFR 172, Subpart H.

HazMat Employee Training Requirements

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PRESENTED BY:

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

A different kind of training.

HazMat Employee Training Requirements

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A Question Before We Start…

•Have you identified, trained, and tested all the HazMat Employees at your facility?

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SOME BACKGROUND INFORMATION:It is first necessary to clear up some potential sources of confusion about the regulations, identify the Agency that enforces them, and to clearly define some key terms.

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OSHA v. US DOT

Occupational Safety & Health Administration

• Regulates safety in the workplace.

• Required training includes:• HazMat Awareness.• OSHA Hazardous

Material.• Hazardous Waste Ope

rations (HAZWOPER).

US Department of Transportation

• Regulates the domestic transportation of hazardous materials.

• Requires triennial training for all HazMat Employees.

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Includes All Methods of Transportation

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What is a Hazardous Material?

• Defined @ 49 CFR 171.8, a hazardous material has been determined by US DOT to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce.

• Hazardous Materials Table @ 49 CFR 172.101.• Includes:

• Hazardous substances.• Hazardous wastes.• Marine pollutants.• Elevated temperature materials.

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More About Hazardous Materials

• Hazardous Substances – refer to 40 CFR 302.4.• Hazardous Waste – any material subject to the hazardous waste manifest requirements of the US EPA. Doesn’t include CESQG’s.

• Marine Pollutants – refer to Appendix B of the Hazardous Materials Table.

• Elevated Temperature Material – refer to 49 CFR 171.8 for full definition.

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Hazardous Materials are Common Materials

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What is a HazMat Employer?

• Employees at least one HazMat Employee, and;

1. Transports a hazardous material in commerce, or;

2. Causes a hazardous material to be transported in commerce,

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Packaging Manufacturers are HazMat Employers

3. Or; designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a hazardous material package or package component.

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WHAT IS A HAZMAT EMPLOYEE?If you are a HazMat Employer you must identify and train your HazMat Employees.

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Defined at 49 CFR 171.8Hazmat employee means: (1) A person who is:

(i) Employed on a full-time, part time, or temporary basis by a hazmat employer and who in the course of such full time, part time or temporary employment directly affects hazardous materials transportation safety;

(ii) Self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting hazardous materials in commerce who in the course of such self-employment directly affects hazardous materials transportation safety;

(iii) A railroad signalman; or

(iv) A railroad maintenance-of-way employee.

(2) This term includes an individual, employed on a full time, part time, or temporary basis by a hazmat employer, or who is self-employed, who during the course of employment:

(i) Loads, unloads, or handles hazardous materials;

(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.

(iii) Prepares hazardous materials for transportation;

(iv) Is responsible for safety of transporting hazardous materials;

(v) Operates a vehicle used to transport hazardous materials.

HUH?!?

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Defined at 49 CFR 171.8Hazmat employee means: (1) A person who is:

(i) Employed on a full-time, part time, or temporary basis by a hazmat employer and who in the course of such full time, part time or temporary employment directly affects hazardous materials transportation safety;

(ii) Self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting hazardous materials in commerce who in the course of such self-employment directly affects hazardous materials transportation safety;

(iii) A railroad signalman; or

(iv) A railroad maintenance-of-way employee.

(2) This term includes an individual, employed on a full time, part time, or temporary basis by a hazmat employer, or who is self-employed, who during the course of employment:

(i) Loads, unloads, or handles hazardous materials;

(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.

(iii) Prepares hazardous materials for transportation;

(iv) Is responsible for safety of transporting hazardous materials;

(v) Operates a vehicle used to transport hazardous materials.

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A HazMat Employee hasPre-Transportation Responsibilities

• Determines the hazard class of a hazardous material.

• Selects a hazardous materials packaging.

• For imports, provides the shipper with information about the regulations.

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A HazMat EmployeeFills & Closes HazMat Packagings

• Fills or loads a hazardous materials packaging.

• Secures a closure on a filled hazardous materials package.

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A HazMat EmployeePrepares HazMat Packagings

• Marks a package to indicate that it contains a hazardous material.

• Labels a package to indicate that it contains a hazardous material.

• Ensures a package is in proper condition for transportation.

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A HazMat EmployeeAssists the Vehicle Driver

• Blocks & braces and segregates a HazMat package in a transport vehicle.

• Selects, provides, or affixes placards for a transport vehicle.

• Places warning signs, blocks wheels, and sets brakes on tank cars for loading or unloading.

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A HazMat EmployeeLoads or Unloads HazMat

This includes the transfer of bulk quantities.

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A HazMat EmployeeProvides Oversight and Supervision

• Certifies that a hazardous material is in proper condition for transportation.

• Supervises HazMat Employees.

• Is responsible for the safety of transporting hazardous materials.

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A HazMat EmployeeHandles Shipping Papers• Prepares a hazardous materials shipping paper.

• Provides and maintains emergency response information.

• Reviews a hazardous materials shipping paper to verify compliance with the regulations.

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Including a Uniform Hazardous Waste Manifest• Prepares a uniform hazardous waste manifest.

• Provides and maintains emergency response information.

• Reviews a uniform hazardous waste manifest to verify compliance with the regulations.

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A HazMat EmployeeManufactures, etc. Packages• Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package or package component.

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What Does a HazMat Employee Do?

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HOW MUST I TRAIN MY HAZMAT EMPLOYEES?Once you’ve identified your HazMat Employees, you must ensure they are trained and tested per the requirements of 49 CFR 172, Subpart H.

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The HazMat Employee Training Requirements

• Required since 1992.• Revised in 2003 & again in 2010.

• Further revisions proposed for some HazMat Employee job descriptions.

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Training Requirements of49 CFR 172, Subpart H

General Awareness/Familiarization

Function-Specific Responsibilities

Safety & Emergency Response

Security General Awareness

In-Depth Security

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Training Requirements of49 CFR 177.816

Professional Driving Skills

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• Training that provides familiarity with the general requirements of the HMR and enables the HazMat Employee to recognize and identify hazardous materials.

• All HazMat Employees must receive general awareness training.

General Awareness/Familiarization

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• Training that provides a detailed understanding of HMR requirements applicable to the function(s) performed.

• Each HazMat Employee must be trained on the specific functions they are required to perform.

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• Training that covers the hazards presented by hazardous materials, safe handling, emergency response information, and methods and procedures for accident avoidance.

• All HazMat Employees must receive this training.

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• Training that provides a general understanding of the security risks associated with HazMat transportation, the methods designed to enhance transportation security, and how to recognize and respond to possible security threats.

• Since 2003 all HazMat Employees must receive this training.

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• Training that provides a detailed understanding of a company’s security plan including company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach and the organizational security structure.

• This training must be provided to HazMat Employees who handle or perform regulated functions related to the transportation of the materials covered by the security plan or who are responsible for implementing the security plan.

HazMat Employee Training Requirements

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Security Plan/In-Depth Security Training Applicability

• Applicability determined by type and amount of hazardous materials shipped.

• Applicability determination revised: 10.1.10.

• Refer to 49 CFR 172.800(b).

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HazMat Employee Training Requirements• Full training every 3 years.• Must receive training within 90 days of employment or new job assignment. Supervised in that time.

• HazMat Employee must be tested as part of training.

• HazMat Employer ensures training and testing is adequate and appropriate.

• No training or experience requirement for trainer.

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HazMat Training Documentation

• Hazmat employee’s name. • Most recent training completion date.

• Description, copy, or location of the training materials.

• Name and address of person providing the training.

• “Certification” that the HazMat Employee has been trained and tested.

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HazMat Training Document Retention

• Current employees until facility closure.

• Former employees at least 90 days from last day.

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For More Information

1. What You Should Know: A Guide To Developing A Hazardous Materials Training Program

2. Does Your HazMat Training Measure Up?

3. US DOT website: HazMat Employee Training Requirements.

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Contact me to learn more.

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

Any Questions?

This concludes my presentation: HazMat Employee Training Requirements

@DanielsTrainingHazMat Employee Training Requirements