The Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) requires two types of training for hazardous materials (hazmat) employees. First, all hazmat employees must receive general training as described at 49 CFR Section 172.704(a)(1)-(4). Second, Section 172.704(a)(5) states that employers who must have a security plan are required to provide in-depth security training to their hazmat employees.
A hazmat employee is defined at 49 CFR Section 171.8 and includes any full-time, part-time, or temporary employee who directly affects hazmat transportation safety; loads, unloads, or handles hazmat; designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests hazmat packaging; prepares hazmat for transportation; or operates a vehicle used to transport hazmat.
Given the wide number of actions that define a hazmat employee, some organizations may have many individuals who must receive general training. Therefore, it is imperative that employers know which of those employees must also receive in-depth security training.
All hazmat employees
Each hazmat employer must train and test their hazmat employees, certify their training, and develop and retain records of current training. Hazmat training must include:
- General awareness/familiarization training. This is intended to provide familiarity with the federal hazmat requirements and enable the identification of hazmat.
- Function-specific training.Specific functions may include hazard classification, marking, labeling, placarding, packaging, or preparing shipping papers.
- Safety training. This covers emergency response information, measures to protect the employee from the hazards associated with hazmat, and methods and procedures for avoiding accidents
- Security awareness. Each hazmat employee must receive training on how to be aware of both security risks associated with hazmat transportation and the methods designed to enhance transportation security. This training must include a component covering how to recognize and respond to possible security threats. New hazmat employees must receive security awareness training within 90 days after employment.
In-depth security training
The in-depth security training requirements for employees apply to employers that are required to have a security plan under 49 CFR Section 172.800. Under Section 172.800(b), security plans must be in place whenever a person offers for transportation in commerce or transports in commerce one or more of 16 listed hazmats that are either (1) in large bulk quantity (i.e., greater than 3,000 kilograms [6,614 pounds] for solids or 3,000 liters [792 gallons] for liquids and gases) in a single packaging, such as a cargo tank motor vehicle, portable tank, tank car, or other bulk container; (2) in any quantity (e.g., materials poisonous by inhalation or organic peroxide); or (3) in a quantity requiring placarding (e.g., desensitized explosives or uranium hexafluoride).
Section 172.704(5) states that the in-depth security training must include company security objectives, organizational security structure, specific security duties, responsibilities for each employee, and specific actions to be taken by each employee in the event of a security breach.
The single exception to the requirement to have a security plan when any of the above factors apply is for a farmer who generates less than $500,000 annually in gross receipts from the sale of agricultural commodities or products. The exception applies only when the transportation activities are conducted by highway or rail, in direct support of the farming operations, and within a 150-mile radius of those operations.
In-depth security training is required only for hazmat employees who handle or perform regulated functions related to transportation of the materials listed in Section 172.800(b) or who are responsible for implementing the security plan.
A new employee may perform hazmat job functions before completing training provided the employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee. Recurrent training is required at least once every 3 years. The 3-year period begins on the actual date of training. Relevant training received from a previous employer or source may be used to satisfy the requirements provided a current record of training is obtained from the previous employer or other sources.
Training conducted by the Occupational Safety and Health Administration (OSHA), the EPA, or other federal or international agencies may be used to satisfy the training requirements in Section 172.704(a) to the extent that such training addresses the components specified in this section (i.e., general awareness/familiarization, function-specific, safety, security awareness, in-depth security training if a security plan is required, and driver training for each hazmat employee who will operate a motor vehicle).
PHMSA’s brochure, Hazardous Materials Transportation Security Requirements provides general guidance about meeting the hazmat training requirements. The brochure was released in 2010 after PHMSA issued a final rule narrowing the list of materials subject to security plan requirements based on the security threats those materials posed.