What are Hazardous Materials?
Whether you are self-employed or work for a large company, you may have to transport hazardous materials as part of your job responsibilities. Hazardous materials are defined by the Department of Transportation (DOT) as “a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under Section 5103 of Federal Hazardous Materials Transportation Law (49 U.S.C. 5103).” This includes strong alkaline and acidic detergents, solvents, and other materials related to the cleaning equipment trade.
Engaging in transportation of hazardous materials without proper training for employees is consistently near the top of the list of most common DOT citations each year. This is partly because of the extensive list of agencies that also monitor hazardous materials, including but not limited to:
• United States Federal Aviation Administration (FAA)
• United States Federal Motor Carrier Safety Administration (FMCSA)
• United States Federal Railroad Administration (FRA)
• United States Occupational Safety and Health Administration (OSHA)
• United States Environmental Protection Agency (EPA)
With all of these agencies monitoring the materials that we carry in various types of vehicles on public roadways, it is no surprise that proper training of employees plays such a vital role in avoiding citations and fines.
How to do Developing Training for Hazmat Employees
The Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185), issued by the DOT’s Pipeline and Hazardous Materials Administration (PHMSA), outlines the requirements that govern the commercial transportation of hazardous materials by highway, railway, vessel, and air. The HMR regulates the training requirements for people who prepare hazardous materials for shipment or transportation in commerce. The intent of the regulations is to ensure that all hazmat employees are familiar with the HMR, are able to identify hazardous materials, understand the specific requirements which apply to the job function they are to perform, as well as being knowledgeable about emergency response and accident prevention methods. Hazmat employers and hazmat employees are defined in 49 CFR §171.8. The training requirements are located in Subpart H of Part 172 of the HMR (49 CFR). The HMR are performance-based and provide a baseline set of training requirements. It is up to the employer to determine the level of training for each employee, depending on their function in the hazmat transportation process (Gantt).
What is a Hazmat Employee?
The first important step to take when developing training is determining which of your employees are considered hazmat employees. While the HMR provides definitions such as pre-transportation functions, it does not define what these functions include. However, the HMR does host a list of job functions (49CFR §171.8) that would be considered pre-transportation functions. This list includes, but is not limited to, a person who:
• Selects a hazardous materials packaging
• Fills or loads a hazardous materials package
• Labels a package to indicate that it contains a hazardous material
• Prepares a hazardous materials shipping paper
• Loads, unloads, or handles hazardous materials for the purpose of transportation
• Operates a vehicle used to transport hazardous materials. (PHMSA)
Now that hazmat employees have been identified, the second step should shift to the task of developing the training required by the Hazardous Materials Regulations (HMR). Training requirements are defined in the HMR (49 CFR Subpart H). The requirements can be broken down into four key types:
General Awareness/Familiarization: Each hazmat employee shall be provided general awareness/familiarization training designed to provide familiarity with the requirements of this subchapter, and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards of this subchapter.
Function Specific: Each hazmat employee must be provided function-specific training concerning requirements of the regulations that pertain to their specific function. For example, employees who fill hazardous materials packaging must be trained in the general practices of packaging and packages.
Safety: Each hazmat employee shall receive safety training concerning emergency response information, safe handling, as well as methods and procedures for avoiding accidents.
Security: Each hazmat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats.
New hazmat employees must receive the required training required by this regulation within 90 days of employment. “A new hazmat employee, or a hazmat employee who changes job functions may perform those functions prior to the completion of training provided – (i) that the employee performs those functions under the direct supervision of a properly trained and knowledgeable hazmat employee; and – (ii) the training is completed within 90 days after employment or a change in job function” (49 CFR §172.704 (c)(1)).
What is a Hazmat Employer
Once a company determines that it is a hazmat employer and that they must train their employees, the next step is determining the employee’s training needs. Questions that an employer should ask themselves include:
• What hazardous materials/waste does your company handle, and what hazards do they represent?
• What modes of transport do you use?
• Where do you transport these hazardous materials (i.e. domestic or international)?
• What are the job descriptions of you hazmat employees?
• Does your company’s accident or injury rate indicate the need for additional training? If so, in what areas?
• Are your employees aware of incident reporting requirements?
• Have your hazmat employees been previously trained?
Once these questions have been answered, a method of training should be selected that will facilitate the need of the hazmat employees. There are many methods of delivery, but the most prevalent include web-based, classroom, and hands-on/mentor training.
Why Spend Time Creating Quality Training in Hazmat Employees?
Developing the content for the training can be a daunting task. For this reason, many hazmat employers opt to have their employees trained by a third party. However, if employees receive poor or inaccurate training, the hazmat employer is responsible, as it is the responsibility of the employer to determine the delivery and content of training. Networking is your greatest ally in this aspect of development. Utilize other companies within your service area who use third-party trainers, and request feedback regarding the level of comprehension, as well as the employee’s perception of the training they attended. Firsthand accounts are the best tool when selecting a training facility. Also, supervisors’ observations are extremely helpful in assessing the employees’ level of understanding and retention. “You get what you pay for” is something to keep in mind when researching third-party training centers.
Hazardous materials transportation training is an often overlooked aspect of the cleaning industry; however, failure to train can be a costly mistake in the event of an accident. By following the simple steps outlined above for determining whether your company is a hazmat employer, who your hazmat employees are, and lastly what type of training needs to be covered, you will be able to lower your risk of incident and breathe easier, knowing that your employees are knowledgeable in their hazmat-related functions.
Drew Harbour is the Safety Manager for Chappell Supply and Equipment in Oklahoma City, OK. Chappell Supply and Equipment strives for excellence through the safe production, maintenance and service of all product lines. Chappell Supply and Equipment goes the extra mile to ensure that all employees are trained in the safe work practices and operations for any and all jobs they are to perform. HazMat training, HAZWOPER First Responder, Fall Protection, Confined Space, Lockout/Tagout, and First Aid are just an example of the extensive training Chappell Supply and Equipment employees participate. These trainings ensure that our employees are capable and competent in the safety procedures to comply with all of our customer’s requests. For more information, call (405) 495-1722 or visit www.chappellsupply.com.
49 CFR. ECFR. 9 June 2013. 11 June 2013. <http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=/ecfrbrowse/Title49/49cfrv2_02.tpl>.
Gantt, Ron. “HazMat Transportation.” Professional Safety (2013): 68-75. Magazine.
PHMSA. Pipeline and Hazardous Materials Safety Administration. n.d. 10 June 2012. <http://phmsa.dot.gov/hazmat>.