26 Spray January 2017 Steven Charles Hunt President, ShipMate, Inc. From here to there: Topics in Transportation 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 & 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
Spray January 2017
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