The Pipeline and Hazardous Materials Safety Administration’s (PHMSA’s) hazmat training requirements are nonspecific. But one thing is crystal clear: You are legally responsible for making sure hazmat employees are properly trained.
According to PHMSA regulations, hazmat training should ensure that employees can identify hazardous materials, understand regulatory requirements, know how to prevent accidents, and know what to do in an emergency.
But beyond that, there are relatively few explicit training provisions. So what should training cover? Your program should focus on five specific areas:
- General awareness/familiarization training
- Function-specific training
- Safety training
- Security awareness training
- In-depth security training
The first four are mandatory for all hazmat workers. The last is mandatory for employees who perform regulated functions related to the transportation of materials covered by the hazmat security plan, or who are responsible for implementing the security plan.
Employees should be tested on the training material, although there is no requirement that testing be scored. In addition, you have to provide refresher training at specific intervals and keep training records.
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Compliance Tips
Here are some recommendations from PHMSA that can help you make the right choices in your training program.
Make a plan. PHMSA suggests your plan include a statement of purpose and the benefits of thorough and regular employee training. The plan should also include specific directions for evaluating the effectiveness of training and instructions for completing administrative tasks, such as recordkeeping and scheduling.
Identify hazmat employees. According to PHMSA, hazmat employees are those who:
- Determine the hazard class of a hazmat.
- Select hazmat packaging.
- Place warning signs, block wheels, and set brakes on tank cars for loading or unloading with closures open.
- Mark packages to indicate that they contain hazmats.
- Provide and maintain hazmat emergency response information.
- Provide international shippers with information on U.S. hazmat requirements.
- Segregate a hazmat package in a freight container or transport vehicle from incompatible cargo.
- Load or unload hazmats for the purpose of transportation.
Conduct a needs assessment. Before training, determine issues such as the level of awareness hazmat employees have about hazards and safety requirements, as well as the level of training they’ve already had. Also find out if previous training is adequate for tasks they are now performing. If your operations have changed since the last round of training, determine if new training has occurred to accommodate changes.
Select a training tool. PHMSA suggests four training delivery methods:
- Web-based
- Computer-based
- Classroom
- Hands-on/mentor training
Evaluate the effectiveness of training. A training program is only as good as the results it produces. Find out from employees how they benefited from training, and observe whether training has been incorporated into their on-the-job performance.
Assign a training manager. Responsibilities can include arranging for newly trained employees to be evaluated, determining additional training needs, communicating the status of training to upper management, and maintaining required training records.
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PHMSA also urges you to not stop with training. Develop a safety culture that encourages training as part of daily and typical tasks and operations. Attention to regulatory requirements, efficiency, and improved performance invariably begin with demonstrated commitment by top management, followed by buy-in from all other levels in your organization.
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