When hazardous materials are transported in commerce, they fall under the jurisdiction of U.S. DOT. But, employers must also comply with the training requirements of OSHA’s safety and health rules as they apply to conditions at the facility. This makes training your employees properly a little confusing. Don’t leave anyone out. Here’s a breakdown of who needs hazardous materials transportation training at your facility.
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Training for Everyone
You need to offer general awareness training for all employees with any HAZMAT transportation responsibilities. This should include:
- Understanding of the importance of hazardous materials safety, the purpose of HAZMAT transport safety regulations, and why it’s critical to ensure HAZMAT transport safety;
- Recognition and identification of hazardous materials; and
- An awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security.
Function-Specific Training
This training covers the particular knowledge, skills, and abilities each individual needs to do his or her HAZMAT transport tasks properly and safely. Depending on the job, this training can involve such specifics as:
- Loading and unloading hazardous materials safely
- Filling out HAZMAT shipping papers properly
- Selecting and marking containers for shipping
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Safety Training
This level of training is given to people who handle or transport packages containing hazardous materials, including warehouse workers. It is also required for drivers and for railroad crew members and others who would be exposed to hazardous materials if they were in an accident. This level of training covers:
- The hazards of particular materials under normal conditions and potential accident scenarios
- Personal protective equipment (PPE) to use to prevent exposure to hazardous materials
- Ventilation and other controls in place to protect from hazards
- How to perform tasks, such as handling HAZMAT packages, in a way that will prevent accidents
- What to do in an emergency, such as contacting assigned emergency responders and how to use fire extinguishers
Training for Drivers
Special training is given to employees who drive vehicles that carry hazardous materials. Drivers must receive the previous three levels of training plus special training that meets Federal Motor Carrier Safety Regulations pertaining to vehicle inspection and operation; conditions affecting vehicle handling; and crossing tunnels, bridges, and railroads.
In-Depth Security Training
HAZMAT employees of companies required to have a security plan must receive in-depth security training concerning the security plan and its implementation.
HAZWOPER Training
Training provided under DOT’s hazardous material regulations may be used to satisfy OSHA’s HAZWOPER employee training requirements to the extent that the training meets HAZWOPER requirements. Any employees required to drive onto uncontrolled hazardous waste sites, enter EPA-regulated treatment, storage, and disposal facilities, or respond to hazardous waste emergencies, must comply with the HAZWOPER training requirements for those facilities and activities.
Now that you know who needs what training, see tomorrow’s issue of the Environmental Daily Advisor for tips on training records, how often you should train, plus an introduction to 120 ready-to-use training tools.