The Identification and Training of HazMat Employees


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Slightly revised from a similar presentation I gave at the Michigan Safety Conference in 2012. This presentation was provided as an educational session at the Plant and Facilities Maintenance Association (PFMA) 2013 Expo in Milwaukee, WI on February 28th. This information is never out-of-date and will help you to identify the following: What is a hazardous material (HazMat)? Who or what is a HazMat Employer? Who are my HazMat Employees? What training is required for HazMat Employees? All of it is backed up with the Federal regulations of the US DOT found in Title 49 of the Code of Federal Regulations (49 CFR). The presentation concludes with links to additional information on this topic.

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  • A HazMat Employee could be someone who affixes labels or markings to a package, or performs inspections of packages prior to shipment.
  • The Identification and Training of HazMat Employees

    1. 1. HazMat Employee Training Requirements @DanielsTraining 1 THE IDENTIFICATION AND TRAINING OF HAZMAT EMPLOYEES Pursuant to the regulations of the US DOT
    2. 2. HazMat Employee Training Requirements @DanielsTraining 2PRESENTED BY: Daniels Training Services 815.821.1550 A different kind of training.
    3. 3. HazMat Employee TrainingRequirements @DanielsTraining 4 WHAT IS A HAZARDOUS MATERIAL (HAZMAT)? It all begins with the US DOT’s definition of a hazardous material.
    4. 4. HazMat Employee Training Requirements @DanielsTraining 5What is a Hazardous Material?• Defined @ 49 CFR 171.8, as capable of posing an unreasonable risk to health, safety, and property when transported in commerce.
    5. 5. HazMat Employee Training Requirements @DanielsTraining 6Hazardous Materials Include:• Technical Name listed in Hazardous Materials Table.• Exhibits the characteristic of a hazard class or division.• Hazardous Substance• Hazardous Waste• Marine Pollutant• Elevated Temperature Material
    6. 6. HazMat Employee Training Requirements @DanielsTraining 7Hazardous Materials are Common From LQG or SQG
    7. 7. HazMat Employee TrainingRequirements @DanielsTraining 8 WHO OR WHAT IS A HAZMAT EMPLOYER? If you meet the definition of a HazMat Employer, then you are responsible for identifying and training your HazMat Employees.
    8. 8. HazMat Employee Training Requirements @DanielsTraining 9You are a HazMat Employer if…(1.0)• You employ at least one HazMat Employee.and…1. Transport a hazardous material in commerce. Or….
    9. 9. HazMat Employee Training Requirements @DanielsTraining 10You are a HazMat Employer if…(2.0)• You employ at least one HazMat Employee,and…2. Cause a hazardous material to be transported in commerce. Or….
    10. 10. HazMat Employee Training Requirements @DanielsTraining 11Packaging Manufacturers are AlsoHazMat Employers (3.0)3. Design, manufacture , fabricate, inspect, mark, maintain, reco ndition, repair or test a hazardous material package or package component.
    11. 11. HazMat Employee Training Requirements @DanielsTraining 12A HazMat Employer Includes• Any department, agency, or instrumentality of the US.• A state or political subdivision of a state.• An Indian tribe.• An owner/operator of a motor vehicle.
    12. 12. HazMat Employee TrainingRequirements @DanielsTraining 13 WHAT IS A HAZMAT EMPLOYEE? If you are a HazMat Employer you must identify and train your HazMat Employees.
    13. 13. HazMat Employee Training Requirements @DanielsTraining 14 Defined at 49 CFR 171.8Hazmat employee means: (1) A person who is:(i) Employed on a full-time, part time, or temporary basis by a hazmat employer and whoin the course of such full time, part time or temporary employment directly affectshazardous materials transportation safety;(ii) Self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) HUH?!?transporting hazardous materials in commerce who in the course of such self-employment directly affects hazardous materials transportation safety;(iii) A railroad signalman; or(iv) A railroad maintenance-of-way employee.(2) This term includes an individual, employed on a full time, part time, or temporarybasis by a hazmat employer, or who is self-employed, who during the course ofemployment:(i) Loads, unloads, or handles hazardous materials;(ii)Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, ortests a package, container or packaging component that isrepresented, marked, certified, or sold as qualified for use in transporting hazardousmaterial in commerce.(iii) Prepares hazardous materials for transportation;
    14. 14. HazMat Employee Training Requirements @DanielsTraining 15A Breakdown of the Definition (1.0)• Employed full-time, part-time, temporary, or self- employed.and…• Whose job directly affects hazardous material transportation safety.• Also includes… • Railroad signalman. • Railroad maintenance-of-way employee.
    15. 15. HazMat Employee Training Requirements @DanielsTraining 16A Breakdown of the Definition (2.0)• HazMat Employee also includes full-time, part- time, temporary, or self-employed who… • Loads, unloads, or handles hazardous materials; • Involved in any phase of manufacture of HazMat packaging. • Prepares hazardous materials for transportation; • Is responsible for safety of transporting hazardous materials; • Operates a vehicle used to transport hazardous materials.
    16. 16. HazMat Employee TrainingRequirements @DanielsTraining 17 WHAT DOES A HAZMAT EMPLOYEE DO? The regulatory definition is a start, but it also helps to have a description – with pictures! – of the job duties of a HazMat Employee.
    17. 17. HazMat Employee Training Requirements @DanielsTraining 18 A HazMat Employee has Pre-Transportation Responsibilities• Determines the hazard class of a hazardous material.• Selects a hazardous material’s packaging.• For imports, provides the shipper with information about the regulations.
    18. 18. HazMat Employee Training Requirements @DanielsTraining 19A HazMat EmployeeFills & Closes HazMatPackagings • Fills or loads a hazardous materials packaging. • Secures a closure on a hazardous materials packaging.
    19. 19. HazMat Employee Training Requirements @DanielsTraining 20A HazMat EmployeePrepares HazMat Packagings • Marks & labels Markings package to indicate that it contains a hazardous material. • Ensures a package is in proper condition for transportation. HazMat Labels
    20. 20. HazMat Employee Training Requirements @DanielsTraining 21 A HazMat Employee Assists the Vehicle Driver• Loads, unloads HazMat for transportation.• Secures & segregates a HazMat package in a vehicle.• Selects, provides, or affixes placards.
    21. 21. HazMat Employee Training Requirements @DanielsTraining 22A HazMat EmployeeLoads or Unloads HazMat
    22. 22. HazMat Employee Training Requirements @DanielsTraining 23A HazMat Employee Assists inTransportation by Rail • Places warning signs, blocks wheels, and sets brakes on tank cars placed for loading or unloading with closures open.
    23. 23. HazMat Employee Training Requirements @DanielsTraining 24A HazMat EmployeeProvides Oversight and Supervision • Certifies a hazardous material is ready for transportation. • Supervises HazMat Employees. • Is responsible for the safe transportation of hazardous materials.
    24. 24. HazMat Employee Training Requirements @DanielsTraining 25A HazMat EmployeeHandles Shipping Papers• Prepares a hazardous materials shipping paper.• Provides and maintains emergency response information.• Reviews a hazardous materials shipping paper to verify compliance with the regulations.
    25. 25. HazMat Employee Training Requirements @DanielsTraining 26Including a Uniform HazardousWaste Manifest• Prepares a uniform hazardous waste manifest.• Provides and maintains emergency response information.• Reviews a uniform hazardous waste manifest to verify compliance with the regulations.
    26. 26. HazMat Employee Training Requirements @DanielsTraining 27A HazMat EmployeeManufactures, etc. Packages• Designs, manufactures , fabricates, inspects, marks, maintains, reco nditions, repairs or tests a package or package component.
    27. 27. HazMat Employee Training Requirements @DanielsTraining 28A HazMat EmployeeOperates a Vehicle Used to Transporta Hazardous Material
    28. 28. HazMat Employee TrainingRequirements @DanielsTraining 29 HOW MUST I TRAIN MY HAZMAT EMPLOYEES? Once you’ve identified your HazMat Employees, you as the HazMat Employer must ensure they are trained and tested per the requirements of 49 CFR 172, Subpart H.
    29. 29. HazMat Employee Training Requirements @DanielsTraining 30 Training Requirements of 49 CFR 172, Subpart H General Awareness/Familiarization Function-Specific Responsibilities Safety & Emergency Response Security General Awareness In-Depth Security
    30. 30. HazMat Employee Training Requirements @DanielsTraining 31 Training Requirements of 49 CFR 177.816 Professional Driving Skills
    31. 31. HazMat Employee Training Requirements @DanielsTraining 32 General Awareness/Familiarization • Familiarity with the general requirements of the HMR. • Enable a HazMat Employee to recognize and identify hazardous materials.
    32. 32. HazMat Employee Training Requirements @DanielsTraining 33• A detailed understanding of the specific job function(s) of the HazMat Employee.
    33. 33. HazMat Employee Training Requirements @DanielsTraining 34• The hazards presented by hazardous materials.• Safe handling.• Emergency response.• How to avoid accidents.
    34. 34. HazMat Employee Training Requirements @DanielsTraining 35• Security risks associated with HazMat transportation.• Methods to enhance security.• How to recognize and respond to possible security threats.
    35. 35. HazMat Employee Training Requirements @DanielsTraining 36• Applicability determined by type and amount of hazardous materials shipped.• Refer to 49 CFR 172.800(b).
    36. 36. HazMat Employee Training Requirements @DanielsTraining 37• Company security objectives.• Specific security procedures.• Employee responsibilities.• Organizational security structure.and…• Actions to take in the event of a security breach.
    37. 37. HazMat Employee Training Requirements @DanielsTraining 38When Train and How Often? Initial Recurrent• Within 90 days of • Full training at least employment or new once every 3 years. job assignment.• Supervised by trained and knowledgeable personnel in that time.
    38. 38. HazMat Employee Training Requirements @DanielsTraining 39Training Requirements • HazMat Employee must be tested as part of training. • HazMat Employer ensures training and testing is adequate and appropriate. • No training or experience requirement for trainer.
    39. 39. HazMat Employee Training Requirements @DanielsTraining 40HazMat Training Documentation• Specific requirements at 49 CFR 172.704(d).• Retain training record for current employees until facility closure.• At least 90 days from HazMat Employee’s last day.
    40. 40. HazMat Employee Training Requirements @DanielsTraining 41For More Information1. What You Should Know: A Guide To Developing A Hazardous Materials Training Program2. Does Your HazMat Training Measure Up?3. US DOT website: HazMat Employee Training Requirements.
    41. 41. HazMat Employee Training Requirements @DanielsTraining 42This Anyconcludes my Questions?presentation:HazMatEmployeeTrainingRequirementsContact me to Daniels Training Services 815.821.1550learn more.