Steven Charles Hunt President, ShipMate, Inc. from here to there: topics in transportation New GHS HazCom 2012 Training Can Meet DOT General Safety Requirements. The deadline for completing the U.S. Occupational Safety & Health Administration’s (OSHA) Globally Harmonized System for Classification & Labeling of Chemicals (GHS) Hazard Communication Standard (HazCom 2012) training is rapidly approaching. All employers must train those employees who may be exposed to hazardous substances on the product marking, labeling and Safety Data Sheet (SDS) aspects of the new GHS standard which was adopted, in part, on March 26, 2012. Particular attention must be given to the pictograms, and hazard and precautionary statements, as well as the sixteen sections of a properly formatted SDS. 36 Spray September 2013 Testing & Certification Recommended OSHA requires under the new Hazard Communication Standard (HCS) that employers “...provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area.” Although OSHA does not mandate that a written exam or certification be offered in association with the training, employers are strongly encouraged to do so for a number of reasons. First, a written exam is a useful tool to measure comprehension of this most important topic. Additionally, the certification is a method in which to prove to inspecting agencies that the required training was, indeed, given. Second, a written exam and certification may be used to satisfy the U.S. Dept. of Transportation’s (DOT) General Safety Training requirement. DOT requires that all hazmat employees as defined in Title 49, Code of Federal Regulations (CFR), section §171.8, receive General Safety Training, in addition to General Awareness & Familiarization, Security awareness, and Function-Specific training. Driver training and Detailed Security Plan training may also be required for operators of motor vehicles used to transport placardable quantities of dangerous goods, or for facilities that offer into transport or transport quantities of hazardous materials requiring registration with DOT’s Pipeline & Hazardous Materials Safety Administration (PHMSA). In order to qualify for DOT General Safety Training, the training offered must fulfill the requirements of 49 CFR Part 172, subpart H, and sections §172.702 and §172.704, in particular. DOT’s General Safety Training Requirement states that: “...each hazmat employee shall receive training concerning:
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