January 2017

DOT Hazardous Materials Training

Dangerous goods accidents and incidents caused by human error can be substantially reduced by developing, implementing and providing a robust hazardous materials transportation training program.

The U.S. Dept. of Transportation’s (DOT) Hazardous Materials Regulations (HMR) requires training for persons who prepare or transport hazardous materials for transportation in commerce. The intent of the HMR is to ensure that each hazardous material (hazmat) employee is familiar with the HMR, is able to recognize and identify hazmat, understands the specific requirements applicable to the functions he or she performs and is knowledgeable of emergency response procedures, self-protection measures and accident prevention methods. The DOT’s hazardous materials transportation training requirements are outlined in 49 CFR Part 172, Subpart H and include:

General Awareness/Familiarization

This program provides hazmat employees a familiarity with the requirements of the HMR and enables them to recognize and identify hazardous materials consistent with the hazard communication standards. All hazmat employees are required to receive general awareness/familiarization training. This training typically provides a basic understanding of the following topics:

 

  • Identification of Hazardous Materials
  • International Hazard Classification System
  • How to Use the Hazardous Materials Table
  • Packing & Packaging
  • Hazard Communication (marking, labeling, placarding)
  • Shipping Papers
  • Stowage & Segregation
  • Training Requirements
  • Incident Reporting

 

Function-Specific Training

Function-specific training provides hazardous materials employees with a more detailed analysis of the requirements of the HMR as it applies to the function(s) performed by the hazardous materials employees. Training requirements will vary depending upon the company operations and the hazardous materials employee’s responsibilities. The hazardous materials employer must identify the specific topics and extent to which topics are covered to meet its employees’ needs.

 

Safety Training

The DOT General Safety Training program describes the hazards presented by hazardous materials and addresses safe handling, emergency response information and methods and procedures for accident avoidance. Training that meets U.S. Environmental Protection Agency (EPA) and U.S. Occupational Safety & Health Administration (OSHA) regulations may be acceptable in meeting the HMR, provided it addresses DOT hazard communication requirements and the risks associated with DOT-regulated hazardous materials. All hazardous materials employees are required to receive safety training.

 

Topics should include:

 

  • Emergency Response Information
  • Emergency Response Telephone Numbers
  • Means of Egress
  • Employee Emergency Plans & Fire Prevention Plans
  • General Safety and Health Provisions
  • Employee Emergency Action Plans
  • Contract Employer Responsibilities
  • Hazardous Waste Operations & Emergency Response
  • Personal Protective Equipment

 

Security Awareness Training

This training program provides hazardous materials employees with a general understanding of the security risks associated with hazardous materials transportation and the methods designed to enhance transportation security. All hazardous materials employees are required to have security awareness training. Subjects that should be included in this training program are:

 

  • Regulatory Requirements
  • Potential Threats
  • Potential Targets
  • Prevention Tools

 

In-Depth Security Training

The In-Depth Security Plan Training directly relates to the company’s security plan. Specific content is dependent upon the company security plan and the employees’ responsibilities. Hazardous materials employees are required to receive training commensurate with their responsibilities. Training must include:

 

  • Security Objectives
  • Specific Security Procedures
  • Employee Responsibilities
  • Actions to Take in the Event of a Security Breach
  • Organizational Security Structure

 

Delivery Methods

There are many training delivery methods but they can generally be categorized into one of four major types:

 

  1. Web-based
  2. Computer-based
  3. Classroom
  4. Hands-on/Mentor

 

Each delivery method has its advantages and disadvantages. The advantages and disadvantages of web-based and classroom training are compared and contrasted below:

 

Web-Based Training

 

Advantages Disadvantages
·         Provides standardized training ensuring a consistent message ·         Bandwidth limitations can place constraints on certain media types
·         Decreases the time employees are out of the office ·         Hazmat employees must be self-directed and comfortable using the web
·         Allows for quick updates for rapidly changing material ·         Hazmat employees may be distracted or interrupted
·         Training is more accessible to a larger audience ·         It is difficult to provide opportunities for hands-on experience
·         Cost effective way to refresh existing training ·         Some may find it difficult to engage and retain
·         Training is more convenient for employees ·         Limited interaction with an instructor
·         No travel costs ·         Difficult to assess employee progress in real time
·         Little or no cost associated with obtaining new media updates ·         Compatible equipment may not be available

 

Classroom Training

 

Advantages Disadvantages
·         Provides an instructor and a structured approach to teaching ·         Potential personality differences between the trainer and the hazmat employees
·         Allows for real time discussion and provides interaction that isn’t easily duplicated even with the most advanced technology ·         Fellow trainees can dictate the pace of the training, leaving some students behind, and others bored with a pace that is too slow for them
·         Allows for constructive team building ·         Difficult to guarantee outcomes
·         Personalized assistance from the instructor can address individual student needs ·         Scheduling based on trainer or facility availability, not employee needs
·         Leverages instructor skills and experience ·         Costs for travel, training, and the instructor
·         Easy to confirm whether hazmat employees have taken the course  
·         Easy to use evaluation tools to confirm that learning has occurred  
·         Opportunity to customize training to meet employer needs and requirements  

 

Training Effectiveness

An effective hazardous materials transportation training program includes a series of well-written training modules, learning assessments, a comprehensive examination and certification upon successful completion of the course material and examination(s).

An effective training program:

 

  • Promotes a safe workplace and appropriate safe work practices
  • Protects employees, transportation partners, the community and the public
  • Improves a company’s productivity and efficiency
  • Develops employee skills
  • May prevent or reduce civil penalty fines or other sanctions
  • Ensures the safe and secure shipment of hazardous materials
  • Reduces likelihood of a catastrophic event such as fire or explosion
  • Promotes an understanding of why compliance and safety is necessary

 

Facilities should give serious consideration to providing training more frequently than once every three years as these requirements are very dynamic and subject to change in the intervening three-year cycle. Web-based training programs are ideal for this type of training and for training new employees.

 

Instructor Qualifications

Instructor qualifications are also an important element of an effective training program. Dangerous goods instructors may have varying degrees of subject matter expertise and teaching skills. In addition to understanding the subject matter, instructors should understand the best method of delivery for the given audience and be able to effectively communicate very difficult concepts or requirements.

 

Recordkeeping

The hazardous materials employer is responsible for maintaining training records for each hazardous materials employee. These records must be kept for the duration of the three-year training cycle while the hazardous materials employee is employed and for 90 days after the employee changes employment. Training records must be made available by the employer for review of an audit by the regulatory authorities upon request.

Training records must include the following:

  • The hazardous materials employee’s name
  • The most recent training completion date
  • A description of, copy of or reference to the training materials used to meet the training requirements
  • The name and address of the person providing the training
  • A certification that the person has been trained and tested as required

 

For questions regarding hazmat transportation training, contact the DOT Pipeline & Hazardous Materials Safety Administration at (800) 467-4922 or the author at [email protected] or (310) 370-3600.