HazMat Transportation

Go Beyond Training for Loading and Unloading Cargo Tank Vehicles

According to the U.S. Department of Transportation (DOT), more than one-third of hazardous materials transportation violations involve the failure of employers to provide training or maintain employee training records. In most cases, violations are attributed to failure to provide function-specific training. Aside from providing the required training for loading and unloading cargo tank vehicles, there are ways you can go beyond training to ensure that your employees fully understand the safety procedures and requirements for loading and unloading hazardous materials from cargo tank vehicles.

DOT’s training requirements apply to anyone associated with hazardous materials (hazmat) transportation, including those responsible for pretransportation packaging, loading, transporting, and unloading. The employer must make sure that every worker involved with transportation of hazardous materials is trained for his or her specific job function. Employees must receive initial training and additional training when new regulations are adopted, as well as periodic training.

Practice and Feedback

The Pipeline and Hazardous Materials Safety Administration (PHMSA) recommends that an evaluation of employees’ understanding of safe loading/unloading procedures be performed on an annual basis, at a minimum. More frequent and routine practice and evaluation of operating procedures should include observation and feedback by a knowledgeable supervisor on the employee’s performance of covered functions, i.e., those regulated under the HMR; practice sessions; or drills.

Does Your Training Program Include These Basics?

According to PHMSA, at a minimum, a hazmat training program should include provisions to:

  • Identify employees and covered duties, i.e., employees subject to training because of performance of a covered function under the HMR;
  • Observe and evaluate employees’ performance of duties;
  • Provide feedback regarding performance of duties;
  • Establish a performance improvement plan for employees failing to perform up to standard; and
  • Initiate enhanced training if employees are no longer qualified to safely perform covered duties, or if performance of duties contributed to an unintentional release of hazmat.

Let Only Those Who Can Do It Safely, Do It

PHMSA recommends that employers include in the required training record of employees specifics on enhanced training needed, as well as noting when employees safely and successfully perform loading, unloading, or transloading operations. Employers should only use employees who have demonstrated that they can correctly and safely perform these functions.

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