Thomas L. Johnson, CHMM Best Practices for Building a Compliant Hazardous Materials Shipping Program 1

Thomas L. Johnson, CHMM

Best Practices for Building a Compliant Hazardous Materials Shipping Program

1

Objectives

To enable you/your employer to:• Identify hazmat employees/functions• Shape training objectives • Select training methods & materials• Identify costs that come with training

2

Demographics of UIC

• Student body population: ~25,000• Employee body population:~15,000• Teaching hospital• Over 1,400 wet laboratory spaces• EHSO has 18 Full Time Technical Staff

3

UIC Program Challenges

UIC has found it difficult to find staff capable of understanding the complex DOT and ICAO/IATA regulations.

• Difficult to identify all hazmat employees• Difficult to get department “buy-in” for training

4

UIC Program Instructors

• Training responsibility:– Environmental Specialist– Chemical Specialist– Biological Safety Officer– Asst. Director for Chemical Safety

• Program has changed multiple times in the last 5 years

5

Negative Effects of Non Compliance

• Impact of research could be delayed

• Occupational exposure

• Increased enforcement activity against Universities

6

Negative Effects of Non Compliance:

• University of Pennsylvania Health System was fined $7K for improper ground shipments

• Hackensack University Medical Center was fined $9.7K for shipping infectious substances as biomedical waste in unauthorized packaging, as well as for not having training records

7

Negative Effects of Non Compliance:

• University of Michigan Federal Aviation Administration (FAA) received a citation for improper Dry Ice shipments

• Field Environmental Instruments, Inc., (FEI) were charged with willfully causing Federal Express to illicitly transport pressurized gas cylinders by air

8

Who needs DOT/IATA Training?

9

Answer : Hazmat Employees

• Loads, unloads or handles hazmat

• Prepares hazmat for transportation

• Is responsible for the safety of transporting hazmat

IATA DGR Table 1.5.A shows minimum training requirements

DOT & ICAO/IATA defines a Hazmat Employee as a person who:

10

1.Those whose function is to only receive packages (including administrative staff)

2.Dock Workers

3.Researchers (who ship)

4.Hazardous Waste Employees

UIC Hazmat employees are:

11

Hazmat Employee Group Training Course

Administrative Staff & Research Staff, Receiving only

Online “Introduction to Shipping and Receiving” Course

Dock Workers In person “DOT Awareness for Dock Workers” Course

Hazardous Waste Workers In person “DOT Hazardous Waste” Course

Researchers, Shipping clinical samples

In person “Class 6.2 Shipping and Receiving” Program

UIC Hazmat Employees Training Course List

12

UIC administered DOT training in two ways depending on the hazmat employee:

• Self Study

• In Person

Training Methods Employed:

13

DOT Training Method: Self Study, Manual Based

• All new Hazardous Waste hires had to go thru initial training per our departmental Standard Operation Procedure (SOP)

• Training consisted of a single module

14

DOT Training Method : Self Study, Manual Based

Advantages of this style of training:

• Low Cost

• Minimal effort to deliver training

• Training completed on employees’ schedule

15

DOT Training Method: Self Study, Manual Based

Disadvantages of this style of training:

• Little understanding of the regulations

• No 49 CFR on site to reference

• No Student/Instructor interaction

16

DOT Training Method: Self Study, Computer Based

Dept. of Transportation DVD-Rom

17


Advantages of this method:

• Program contained exercises for testing knowledge

• Inexpensive to purchase ($25/disk)

• Training completed on employees’ schedule

18


Disadvantages of this method:• Was limited to few licenses• Employees’ can be distracted or

interrupted• No Student/Instructor interaction

19

Transportation Programs

Without proper documentation and communication, any program runs the risk of no longer being implemented.

UIC experienced this first hand.

20

Reassessment of Class 6.2 Program

Catalyst:•Biological Safety officer leaves campus

Training program abandoned:•International Civil Aviation Organization (ICAO)/International Air Transport Association (IATA) Shipping and Receiving of Class 6.2 materials

21

2008 Goal: Update and Improve Training Program

Possible methods of training:•Self Study- keep current method used

– Saf-T-Pak Reference Manual

•On line•Classroom

22

Infectious Substance Shipping Program Responsibility:

Majority of Universities, this specific program would reside with the Biological Safety Officer

This can also vary university to university:•Environmental Officers•Contractors•Research Office

23

Advantages of the Hazardous Waste Professional Responsible for Class 6.2 Program

1. Already trained in DOT regulations

2. Familiar with selecting proper packages

24

Disadvantages of the Hazardous Waste Professional Responsible for Class 6.2 Program

1. Waste is not allowed to ship via air, so rare to have waste professionals know these rules.

2. Retraining cycle different than DOT (2yrs versus 3yrs)

25

Advantages of the Biological Safety Officer Responsible for Class 6.2 Program

1. Most hazmat shipped via air at a university are biological samples

2. Discovers hazmat employees through IBC review process

3. Best knowledge of infectious organisms

26

Disadvantages of the Biological Safety Officer Responsible for Class 6.2 Program

1. Generally not trained in DOT regulations

2. Not familiar with shipping materials in other hazard classes

27

Advantages to this training method:

•Same as Manual based self study method

28

Disadvantages to this training method:

• Does not explain all pertinent ICAO/IATA regulations (i.e. operator variations)

• Must purchase the updated manual every year

• No way to confirm the employee(s) actually read or understood material

• No reference materials for users to keep

29

Reassessment of DOT Program

Departure of two key departmental employees (Chemical Specialist & Environmental Specialist)

Two programs forgotten:•Dock Worker DOT Training•Hazmat Security Awareness

30

Dock Worker Training Topics

• Recognizing and responding to security threats

• Placarding requirements

• Loading, unloading, segregation rules

• Working with carriers

31

Hazmat Security Awareness

• Little information given

• No mechanism to integrate with other Hazmat training

32

Restructure of Programs

New Asst. Director hired:

•Creates training matrix for UIC laboratory workers

•Trainer sent to DOT/IATA “Train the Trainer” courses

33

Restructuring of Programs

IATA training•Sent to IATA 4 day class to become trainer•Sets aside dept. funds for reference materials •Sets aside dept. funds for refresher training (IATA trainer on 1 yr cycle)

34

IATA Train the Trainer Course

•IATA 4 day class curriculum–Write training objectives and formulate test questions–Prepare visual aids required for the training unit–Understand and apply adult learning principles–High cost class ($3,000) & limited locations

35

Restructuring of 49 CFR trainingPrograms

•Sets aside funds for training materials

•Sets aside funds for formal training of trainer (trainer on 1 yr cycle)

36

Results of Restructuring

37

Current ICAO/IATA Infectious Substance Shipping/Receiving Program

•Classroom setting

•2-3 hours length

•Focuses on Class 6.2 and Dry Ice

•Hands on Approach

38


Materials Provided:

•Copy of presentation slides

•IATA Dangerous Goods Regulations (DGR) sections 1,2,3.6,3.9,6,8

•Pen, Pencil and Highlighter

39


Attendees are shown and work with:•What the proper labels are and how to use them•Differences in UN performance packages•How to cross reference their specific DGR sections•How to create the necessary paperwork

40

Current 49 CFR Program Status

Multiple tracks created depending on task performed

•Administrative staff/Researchers

•Dock worker

•Hazardous Waste worker

41


Administrative and Research staff, receiving only:

•Online Introduction class (1hr)

42


Dock Workers Training: In person at jobsite

•Introduction class (1hr)

•Function specific (1hr)

•Hazmat Safety awareness (1hr)

43


Hazardous Waste Workers Training: Lecture Format

– Introduction class (1hr)– Function specific (8 hr)– Site Specific Hazmat Security awareness (1hr)

Note: Does not include OSHA Hazwoper

44

Advantages to In Person Training

• Provides hands-on experience• More credible training method• Gaps in programs found and can be

corrected• Questions can be presented

45

Disadvantages to In Person Training

• Class schedule conflicts• Can be high cost• Instructor must be available and capable

of training• Large time commitment

46

Program Creation Process

47

Program Costs

Costs vary depending on what method you decide works best for your organization

Computer based self study:– $109 for one software license

Manual based self study:– $165 for a Saf-T-Pak reference manual and

one exam

48

Program Costs

Lecture based training, contractor:– ~$300 per person for a 1 day class

Lecture based training, in house:– ~150-250 hrs. a year dedicated to teaching

and program administration– ~$72 per student trained

49

Building your Training Program Pre Planning:

• Observe building loading docks to see where hazmat is going

• Start to figure out who your hazmat employees are

• Learn if your employer has a preferred shipping vendor (UPS, FedEx)

• Explain to your Dept. Head, Dean, Vice Chancellor the reason for a program

50

Building your Training Program Pre Steps:

It takes a group effort to identify all of your hazmat employees•Laboratory Inspections•IBC Review Process•Laboratory Safety Training•NIH Grant proposals

These are some methods that help to find your hazmat employees

51

Building your Training Program

Step 1 : Define what you needi. Define your site hazmat functions

ii. Define your hazmat employees

iii. Shape your overall training objectives

iv. Shape your function specific training objectives

52


Step 2: Program Selection

• Decide which training method(s) will work best

• Set a realistic training program start date

• Decide where the program(s) will reside

53


Step 3: Program Creation

Core Components for DOT Program

• Function specific• Security Awareness• Record Retention (3 yr)

54


Step 3: Program Creation

Core Components for ICAO/IATA Program

• Function specific• Security Awareness• Airline specific rules• Record retention policy (2 yr)

55


Step 4: Pilot Program•Test your program on a mixed audience

– Include any handouts •Refine the program from the test run(s)•If using computer based method, make sure program works with PC and Macs•Completion certificate should list when trainee is due for refresher

56


Step 5: Roll out•Advertise what your training class is and why someone must attend•For Lecture method-setup multiple days/times for training classes•Use evaluation sheets to improve program•Be ready to defend your program when inspected

57


Step 6: Recordkeeping Requirements•Document your definition of hazmat employee•Copies of your training program materials•Name and address of the trainer•Copy of certification that the trainee was trained and tested as required

58

Issues Seen Moving Forward

1. No back up to take over program(s).

2. No mechanisms for new hire notification.

3. Contractors on campus could ship/receive hazmat.

4. Not capturing all University hazmat employees.

59

Alternative Model: Dangerous Goods Specialist, Central Shipping & Receiving Point

1. Direct control of shipping and receiving of all hazmat for a University.

2. Would need only one person to maintain his/her training instead of multiple individuals.

3. No need to have a university-wide training program with this method.

60

Conclusion

• There is no such thing as a best method• Key to document roles and

responsibilities• Training programs must be living

programs

61

• Floor open to Questions– Contact InformationThomas L. Johnson, CHMM

1140 S. Paulina St.

Rm.245

Chicago, IL 60612

[email protected]

Phone-312-413-2436

Thank you for your time today

62

mailto:[email protected]

Documents

Thomas L. Johnson, CHMM Best Practices for Building a Compliant Hazardous Materials Shipping Program 1