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Hazmat Training Checklist for Compliance

Hazardous Waste Management
by Kelly Lagana
"Yesterday, we talked about what DOT means by the “hazmat employee” and the training involved. Today, we’ve provided a checklist and some questions you should be asking yourself to be sure your hazardous materials training is in compliance with 49 CFR 172, Subpart H."

Are you a “hazmat employer,” i.e., anyone who:

  • Uses one or more workers to transport hazardous materials in commerce?

  • Transports hazardous materials in commerce or causes hazardous materials to be transported or shipped in commerce?
  • Manages packaging that is qualified for transporting hazardous materials (e.g., designs, manufactures, fabricates, inspects, marks, certifies, sells, reconditions, repairs, or tests packages)?

 

If no, you are not responsible for training workers under this rule.


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If yes, have you trained the following “hazardous materials employees”:

  • Anyone who owns or operates a vehicle that transports hazardous materials?
  • Anyone who loads, unloads, or handles hazardous materials?
  • Workers who design, manufacture, fabricate, inspect, mark, maintain, recondition, repair, or test a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce?
  • Workers that prepare hazardous materials for transportation?
  • Anyone who is responsible for the safety aspects of hazardous materials transportation?

Does this training include the following elements:

  • “General awareness/familiarization” training?  
  • “Security awareness” training that provides an awareness of security risks associated with hazmat transportation and methods designed to enhance transportation security?      
  • “Function specific” topics (such as loading and unloading hazardous materials, filling out shipping papers, selecting and marking containers for shipping)?          
  • “Safety training,” including emergency response, personal protection, and accident avoidance?       
  • “Specialized training” for drivers of vehicles that carry hazardous materials?            
  • “In-depth security training” for hazmat employees of companies required to have a security plan?   


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If your company is required to have a security plan, does your in-depth security training include the following elements:

  • Company security objectives?  
  • Specific security procedures?   
  • Specific security duties and employee responsibilities?           
  • Specific actions to be taken by each employee in the event of a security breach?       
  • Your company’s organizational security structure?      

Was the training completed within 90 days of employment?  (Untrained workers may still assume position, as long as supervised by trained and knowledgeable individual.)

For workers that change hazardous-materials duties, will they have completed training in the new hazmat functions within 90 days of making this change?

Have you provided for refresher training:

  • At least once every 3 years?     
  • At least once every 3 years for security plan training ? 
  • Within in 90 days of the implementation of a revised security plan?  

In tomorrow’s Advisor, we give you a hazmat training checklist you can use to make sure you are in compliance with DOT’s hazmat training regs.

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