PHSMA regulations say that, hazmat training must ensure that: “… a hazmat employee has familiarity with the general provisions of this subchapter, is able to recognize and identify hazardous materials, has knowledge of specific requirements of this subchapter applicable to functions performed by the employee, and has knowledge of emergency response information, self-protection measures, and accident prevention methods and procedures.” Beyond this overall objective, however, there are relatively few explicit provisions.
So What Should Training Cover?
Mainly, training must cover five specific areas.
- General awareness/familiarization training
- Function-specific training
- Safety training
- Security awareness training
- In-depth security training
One through four are mandatory for all hazmat employees. Number five 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 must be tested on the material covered in training, although there is no requirement that testing be scored. In addition, employers must ensure that refresher training is conducted at specific intervals and that training records are kept.
How and by whom the training is conducted and the actual contents of training lessons are left to the hazmat employer. While those directions are intentionally nonspecific, the regulations explicitly state that it is the employer and the employer alone that is legally responsible for making sure that employees are provided with the knowledge and skills necessary to perform their hazmat job functions safely.