- Make a plan. PHMSA suggests the plan include a statement of purpose and the benefits of thorough and regular employee training as appropriate to the job function(s), the company, and its resources. The plan should include specific directions on evaluating the effectiveness of training and directions for completing administrative tasks, such as recordkeeping and scheduling.
- Identify hazmat employees. According to PHMSA regulations, hazmat employees include those who:
- Determine the hazard class of a hazmat;
- Select hazmat packaging;
- Place warning signs, block wheels, and set brakes on tank cars placed 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; or
- Load or unload hazmats for the purpose of transportation.
- Conduct a needs assessment before developing a training program. For example, determine the level of awareness hazmat employees have about hazmats and the regulations, as well as the level of training they’ve already had. Also, find out if the training employees have already received is adequate for the tasks they are now performing. If your company’s operations have changed since the last round of training, determine if new employee training has occurred to accommodate the changes.
- Select a training tool. PHMSA’s guidance for hazmat employee training lists four training delivery methods:
- Web-based
- Computer-based
- Classroom
- Hands-on/mentor training
- Evaluate the effectiveness of the training program. A training program is only as good as the results it produces. That means you should ask employees about how they benefited from the training and also 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 for incumbents, communicating the status of training to upper management, and maintaining training records in compliance with PHMSA regulations.
- Don’t 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 begins with demonstrated commitment by top management followed by buy-in from all other levels of the company.
Decisions on which of these, or which combination, is most appro-priate will depend on many factors, including cost, suitability for the hazmat employee and the employee’s hazmat responsibilities, language proficiency, whether employees can be self-directed, and qualifications of the instructor.