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Believe or not, hazmat plays a critical role in our daily lives. Getting those materials from one place to another requires a lot of people and those people must have training. How often is hazmat training required? Let’s take a look.
How often is Hazmat training required for DOT?
Hazmat training must be completed within 90 days for both a new hazmat employee or an employee who changes job functions. Recurrent training is required every 3 years.
Getting hazmat training
If you’re a new employee (whether brand new had a change in job function) you’re allowed to perform hazmat job functions prior to completing hazardous materials training as long as you are under the watchful eye of another employee that has been trained and is knowledgeable about hazardous materials.
The knowledgeable hazmat employee that supervises a new employee doesn’t have to be certified for any specific length of time before they’re allowed to train.
The hazmat employer then has up to 90 days to get you the hazmat training you need to do the job safely.
Here’s something that can speed things up;
If you’ve had relevant hazmat training from a previous employer, you can use that training to satisfy the requirement.
Whether your the hazmat employer or employee, just make sure that you have your current training records on file in case of a DOT audit.
A quick example would be a driver at a propane company who currently has all of his training completed and up to date (and complies with the requirements in 172.704), then decides to switch companies.
He can then take his training records (or his new employer could request them) to his new employer. Since all his hazmat training is up to date he doesn’t need to receive training within 90 days (as long as the job functions are the same).
Recurrent Hazmat Training
Once you’ve had your initial hazardous materials training, it’s required that you have recurrent training every 3 years. The three year clock starts on the date that you received the training.
Recurrent hazmat training is where companies tend to be in violation the most. They provide initial training, but the three years goes by and they forget to make sure that all employee training is up to date.
Failing to provide recurrent hazmat training is one of the biggest violations that an auditor will look for.
Although it’s not required, I would suggest getting training every year. Rules change frequently and people tend to forget things.
DOT hazmat training records; What You Need
It no big surprise;
If you’re an employer that transports hazardous materials you need to have your people trained you need to keep records.
When you receive a DOT audit (remember it’s “when” not “if”) one of the things that will be checked specifically are your training records for hazmat employees that are required in 49 CFR 172.704 (read the rule here).
Your training records can include all kinds of information, but must include the following;
- The employee’s name
- Completion date of the most recent training
- A copy, description and location of the training materials used
- The name and address of the hazmat trainer
- Certification that the hazmat employee has been trained and tested
Record retention for hazmat training
You must maintain the training records for each hazmat employee for three years from the date of the last training. In addition, if the employee leaves the company you must retain their training records 90 days after the employee leaves.
What is DOT hazmat training
DOT hazmat training is general awareness and function specific training that will help prevent or reduce hazardous material transportation incidents that are caused by human error.
Let’s talk a little about human error-
The whole hazmat transportation process is full of people performing a multitude of tasks from handling, storing, packaging, transporting, loading and unloading. Of course, this means the potential for a lot of human error.
There are several things that can factor into Human error:
- Lack of knowledge that leads to mishandling of hazardous materials
- Lack of knowledge how to respond to an incident should there be one
- Not following established safety procedures and guidelines
- Failing to understand one’s role if an incident occurs
- Lack of awareness that hazardous materials are present
- No knowledge that lead to undeclared shipments
Making sure that you’re following the rules by either providing people training or making sure that you receive training (and taking it seriously) can go a long way to help reducing hazmat incidents caused by human error.
Getting hazmat training will not only help reduce human error, but also keeps employees safe, protects the public and helps carriers/shippers manage their risk.
We’ve established already that if you perform a hazardous materials job function such as transportation or packaging that you need hazmat training.
Take hazmat training seriously
Hazardous materials are nothing to mess around with no matter how ‘innocent’ or harmless the product may seem (I’m looking at you diesel fuel).
Not paying attention for a second while you’re performing a task can lead to serious consequences that get yourself or someone else injured. The whole point of all these rules is to keep people safe.
Even if it is ‘just diesel’.
So now the big question – who’s considered a hazmat employee?
Glad you asked…
Who is considered a hazmat employee?
If you’re trying to figure out whether you’re a hazmat employee or you have hazmat employees the DOT rules are pretty straightforward.
Hazmat employee is a person that’s employed by a hazmat employer (you can read the definition here) or a person that’s self-employed who directly affects hazardous materials transportation safety.
- Owner operator of a motor vehicle that transports hazmat
A Person that:
- Loads and unloads hazardous materials
- Designs, manufactures, repairs, marks or represents that packagings are qualified to be used in hazardous materials transportation.
- A person responsible for hazmat transportation safety
- Operates a vehicle that’s used to transport hazardous materials.
Here’s a few examples of people who might be hazmat employees. Keep in mind that this isn’t an all inclusive list.
- Drivers (trucks or other vehicles)
- Warehouse personnel
- Office personnel; People who prepare paperwork or dispatch
What should the training consist of?
The hazardous materials regulations (HMR) is pretty extensive, so where do you begin?
There are 5 general areas of hazmat training that should be offered to or received by employees that will meet DOT training requirements.
- General Awareness and familiarization training.
- Function specific training
- Safety training
- Security awareness training
- In depth security training
Let’s take a quick look at each of these.
General Awareness and familiarization training
This type of training gives the person just the very basics they need to be familiar with the general requirements of the hazmat rules.
Learning the the nine hazard classes would fall under this type of training.
General awareness training helps people to learn, recognize and identify hazmat.
For trucks drivers, when you tested to get your a hazmat endorsement for your CDL, that served as your general awareness training.
DOT Hazmat Function Specific Training
Function specific hazmat training gives the hazmat employee a more detailed understand of the rules in the hazmat regulations (the HMR) that apply to the specific job function they perform.
Here are a couple of examples:
- Propane truck driver loading and unloading propane
- Person in the office who is responsible for preparing shipping papers
- Driver who needs to apply DOT placards on the side of a vehicle
- Someone who fills and/or loads hazmat into package or container
- Marks a hazmat packaging
- Labels a hazmat package
You get the idea.
Every employee has to be trained and understand the hazmat regulations for the specific job they perform.
This type of training should cover the hazards that are presented by hazardous materials.
If your company hauls a specific hazardous materials product frequently (gasoline for example), you’ll want to tailor the training to all of the properties of that hazmat in addition to other materials you may transport.
Providing safety training also includes how to safely handle hazmat, procedures for avoiding accidents and emergency response information (the North American Emergency Response Guide book is a good example).
Every hazmat employee needs safety training.
Security Awareness Training
After 911 DOT required companies to provide security awareness training which is designed to provide an understanding of security risks that are associated with hazardous materials.
- Where should you park a vehicle with hazardous materials?
- How to keep employees safe
- Recognizing potential security threats
As always, every employee must be trained.
In Depth Security Training
In depth security training goes deeper than basic security awareness training.
For in depth training, a company needs to provide training on it’s specific security plan. Your company does have a security plan right?
If your company hauls hazardous materials, you must have a security plan. Failure to have a plan can result in hefty fines during a DOT audit.
This training should provide a good understanding of the company’s security objectives, employee responsibilities, specific safety procedures and actions that must be taken in the event of any kind of security breach.
A company must provide this training to any hazmat employee that handles and performs functions that are regulated and related to hazmat transportation that’s covered by the security plan.
Company officials who are responsible for implementing the company’s security plan also much be trained and have an in depth knowledge of how the execute the plan.
Hazmat transportation is a complex process that involves a lot of people doing a variety of different jobs related to dealing with hazardous materials.
From preparing paperwork, handling, storing, moving, loading/unloading and storing hazmat there is a log of room for human error.
How often is hazmat training required vs How often it should be done can be two different things.
DOT sets minimum standards for ensuring that company’s provide training to employees that if not adhered to, can result in significant fines in an audit.
However, if you want to help keep your risks low and your employees as safe you should train hazmat employees as often and as detailed as possible.