The Identification and Training of HazMat Employees

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THE IDENTIFICATION AND TRAINING OF HAZMAT EMPLOYEESPursuant to the regulations of the US DOT

HazMat Employee Training Requirements

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PRESENTED BY:

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

A different kind of training.

HazMat Employee Training Requirements

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WHAT IS A HAZARDOUS MATERIAL (HAZMAT)?It all begins with the US DOT’s definition of a hazardous material.

HazMat Employee Training Requirements

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What is a Hazardous Material?

• Defined @ 49 CFR 171.8, as capable of posing an unreasonable risk to health, safety, and property when transported in commerce.

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Hazardous Materials Include:

• Technical Name listed in Hazardous Materials Table.

• Exhibits the characteristic of a hazard class or division.

• Hazardous Substance• Hazardous Waste• Marine Pollutant• Elevated Temperature Material

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Hazardous Materials are Common

HazMat Employee Training Requirements

From LQG or SQG

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WHO OR WHAT IS A HAZMAT EMPLOYER?If you meet the definition of a HazMat Employer, then you are responsible for identifying and training your HazMat Employees.

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You are a HazMat Employer if…(1.0)

• You employ at least one HazMat Employee.

and…

1. Transport a hazardous material in commerce.

HazMat Employee Training Requirements

Or….

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You are a HazMat Employer if…(2.0)

• You employ at least one HazMat Employee,

and…

2. Cause a hazardous material to be transported in commerce.

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Or….

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Packaging Manufacturers are Also HazMat Employers (3.0)

3. Design, manufacture, fabricate, inspect, mark, maintain, recondition, repair or test a hazardous material package or package component.

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A HazMat Employer Includes

• Any department, agency, or instrumentality of the US.

• A state or political subdivision of a state.• An Indian tribe.• An owner/operator of a motor vehicle.

HazMat Employee Training Requirements

If they offer a HazMat for transportation or transport in commerce

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WHAT IS A HAZMAT EMPLOYEE?If you are a HazMat Employer you must identify and train your HazMat Employees.

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Defined at 49 CFR 171.8Hazmat employee means: (1) A person who is:

(i) Employed on a full-time, part time, or temporary basis by a hazmat employer and who in the course of such full time, part time or temporary employment directly affects hazardous materials transportation safety;

(ii) Self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting hazardous materials in commerce who in the course of such self-employment directly affects hazardous materials transportation safety;

(iii) A railroad signalman; or

(iv) A railroad maintenance-of-way employee.

(2) This term includes an individual, employed on a full time, part time, or temporary basis by a hazmat employer, or who is self-employed, who during the course of employment:

(i) Loads, unloads, or handles hazardous materials;

(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.

(iii) Prepares hazardous materials for transportation;

(iv) Is responsible for safety of transporting hazardous materials;

(v) Operates a vehicle used to transport hazardous materials.

HUH?!?

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A Breakdown of the Definition (1.0)

• Employed full-time, part-time, temporary, or self-employed.

and…• Whose job directly affects hazardous material transportation safety.

• Also includes…• Railroad signalman.• Railroad maintenance-of-way employee.

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A Breakdown of the Definition (2.0)

• HazMat Employee also includes full-time, part-time, temporary, or self-employed who…• Loads, unloads, or handles hazardous materials;• Involved in any phase of manufacture of HazMat packaging.

• Prepares hazardous materials for transportation;• Is responsible for safety of transporting hazardous materials;

• Operates a vehicle used to transport hazardous materials.

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WHAT DOES A HAZMAT EMPLOYEE DO?The regulatory definition is a start, but it also helps to have a description – with pictures! – of the job duties of a HazMat Employee.

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A HazMat Employee hasPre-Transportation Responsibilities

• Determines the hazard class of a hazardous material.

• Selects a hazardous material’s packaging.

• For imports, provides the shipper with information about the regulations.

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A HazMat EmployeeFills & Closes HazMat Packagings

• Fills or loads a hazardous materials packaging.

• Secures a closure on a hazardous materials packaging.

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A HazMat EmployeePrepares HazMat Packagings

• Marks & labels package to indicate that it contains a hazardous material.

• Ensures a package is in proper condition for transportation.

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HazMat Labels

Markings

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A HazMat EmployeeAssists the Vehicle Driver

• Loads, unloads HazMat for transportation.

• Secures & segregates a HazMat package in a vehicle.

• Selects, provides, or affixes placards.

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A HazMat EmployeeLoads or Unloads HazMat

HazMat Employee Training Requirements

This includes the loading or unloading of bulk quantities

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A HazMat Employee Assists in Transportation by Rail

• Places warning signs, blocks wheels, and sets brakes on tank cars placed for loading or unloading with closures open.

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A HazMat EmployeeProvides Oversight and Supervision

• Certifies a hazardous material is ready for transportation.

• Supervises HazMat Employees.

• Is responsible for the safe transportation of hazardous materials.

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A HazMat EmployeeHandles Shipping Papers• Prepares a hazardous materials shipping paper.

• Provides and maintains emergency response information.

• Reviews a hazardous materials shipping paper to verify compliance with the regulations.

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Including a Uniform Hazardous Waste Manifest• Prepares a uniform hazardous waste manifest.

• Provides and maintains emergency response information.

• Reviews a uniform hazardous waste manifest to verify compliance with the regulations.

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A HazMat EmployeeManufactures, etc. Packages• Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package or package component.

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A HazMat EmployeeOperates a Vehicle Used to Transport a Hazardous Material

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HOW MUST I TRAIN MY HAZMAT EMPLOYEES?Once you’ve identified your HazMat Employees, you as the HazMat Employer must ensure they are trained and tested per the requirements of 49 CFR 172, Subpart H.

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Training Requirements of49 CFR 172, Subpart H

General Awareness/Familiarization

Function-Specific Responsibilities

Safety & Emergency Response

Security General Awareness

In-Depth Security

HazMat Employee Training Requirements

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Training Requirements of49 CFR 177.816

Professional Driving Skills

31HazMat Employee Training Requirements

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• Familiarity with the general requirements of the HMR.

• Enable a HazMat Employee to recognize and identify hazardous materials.

General Awareness/Familiarization

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• A detailed understanding of the specific job function(s) of the HazMat Employee.

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• The hazards presented by hazardous materials.

• Safe handling.• Emergency response.• How to avoid accidents.

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• Security risks associated with HazMat transportation.

• Methods to enhance security.

• How to recognize and respond to possible security threats.

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• Applicability determined by type and amount of hazardous materials shipped.

• Refer to 49 CFR 172.800(b).

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• Company security objectives.• Specific security procedures.• Employee responsibilities.• Organizational security structure.

and…• Actions to take in the event of a security breach.

HazMat Employee Training Requirements

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When Train and How Often?

Initial

• Within 90 days of employment or new job assignment.

• Supervised by trained and knowledgeable personnel in that time.

Recurrent

• Full training at least once every 3 years.

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Training Requirements

• HazMat Employee must be tested as part of training.

• HazMat Employer ensures training and testing is adequate and appropriate.

• No training or experience requirement for trainer.

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HazMat Training Documentation

• Specific requirements at 49 CFR 172.704(d).

• Retain training record for current employees until facility closure.

• At least 90 days from HazMat Employee’s last day.

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For More Information

1. What You Should Know: A Guide To Developing A Hazardous Materials Training Program

2. Does Your HazMat Training Measure Up?

3. US DOT website: HazMat Employee Training Requirements.

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Contact me to learn more.

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

Any Questions?

This concludes my presentation: HazMat Employee Training Requirements

@DanielsTrainingHazMat Employee Training Requirements