If your employees are involved with hazardous materials, you must ensure that your employees receive appropriate training. This means ALL employees who meet DOT’s definition of “hazmat employees.” A hazmat employee is a person who is employed by a hazardous materials employer and “directly affects hazardous materials transportation safety. This is a broad definition, for example, an office assistant who types the required hazardous materials description on a shipping paper at the direction of another is a hazmat employee and must be trained, tested, and certified. Did you know that? If not, you may need to seek some advice from an experienced trainer who can help you with this complex regulatory issue.
The regulations clearly intend that any individual who has any impact on the safety of hazmats in transportation is considered a hazmat employee who requires training and certification.
HAZMAT EMPLOYER MUST
- train and test
- develop and retain records of current training (inclusive of preceding three years) for each hazmat employee (during the period of employment and 90 days thereafter)
TRAINING MUST INCLUDE
- General awareness/familiarization
- Function-specific, training
- Security awareness
- In-depth security training, if a security plan is required
- Driver training (for each hazmat employee who will operate a motor vehicle)
- Is required at least once every three years. The three year period begins on the actual date of training.
- Relevant training received from a previous employer or other source may be used to satisfy the requirements, provided a current record of training is obtained from the previous employer or source (i.e., OSHA, EPA, and other Federal or international agencies.) Training must address components specified in 172.704(a) of the HMR to be considered applicable.
Many training providers offer HAZMAT employee training online, however it is important to note that taking an online class may NOT satisfy the DOT’s training requrirements. That’s because many online training courses don’t offer function-specific training as required under the statute. As an employer you may be unwittingly exposing yourself to potential regulatory fines and citations due to the easy access of cheap online training providers who are all too eager to collect fees without necessarily providing all the elements to regulatory compliance training program.
As an employer you need to ask the tough questions of your training provider and don’t take their answer at face value if it seems ‘to good to be true’. Review all of DOT’s training requirements, before you check this training off your “to do” list.