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  • Reference Information
    The following letters of interpretation provide information regarding safety and health jurisdiction for OSHA and DOT :
    July 10, 1989 - Review of Policy on Section 4(b)(1) of the Act: Pertains to the DOT’s Motor Carrier Safety Act and related statutes, a review of OSHA case law relating to truck drivers, and a summary of applicable 4(b)(1) case law including those upholding the “gap theory” and “hazard-by-hazard” approach.
    November 9, 1990 - Jurisdiction issues involving the Southwest Transportation Company, Inc.
    April 1, 1991 - Jurisdictional Issue - Southwest Transportation
    August 2, 1991 - The working environment of railroad train environment
  • This first section is an overview of the material that will be presented. It reviews the requirements of the standard.
  • The regulation states that each hazmat employee must be provided general awareness/familiarization training designed to provide familiarity with the requirements of this subchapter, and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards of this subchapter. In other words, first you have to relate what the standard says and then you must train the driver/employee in the hazards of the chemicals that they may be exposed to in the course of conducting their job duties.
  • HM 171.8 definitions:
    Hazardous material means a substance or material, which has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated. The term includes hazardous substances, hazardous wastes, marine pollutants, and elevated temperature materials
    Hazardous substance –complicated listing but specifically says that it does not include crude oil or any fraction thereof, natural gas, Liquefied natural gas or synthetic gas usable for fuel.
  • Hazardous Materials Training by

    1. 1. Hazardous Materials Training January 2011
    2. 2. Part One Overview of hazardous materials regulations (HMR) training requirements
    3. 3. Regulatory bodies that govern the transportation of hazardous materials OSHA-concerned with protecting the employee DOT-concerned with the safe transport of hazardous materials (via air, rail, roadway) EPA (DEP)-concerned with protecting the environment NFPA 58 concerned with bulk storage of Propane All require written plans, formal training, emergency response procedures
    4. 4. OSHA or DOT Jurisdiction OSH Act • Section 4(b)(1) of the OSH Act states that OSHA does not have jurisdiction over health and safety if another Federal agency exercises its statutory authority in this area. U.S. courts interpret the OSH Act using the “gap theory” or “hazard-by-hazard” approach: • If DOT has a regulation that would reduce or eliminate the workplace hazard, DOT regulations apply. • If DOT does not have a regulation to address the hazard, OSHA regulations apply.
    5. 5. OSHA or DOT Jurisdiction • DOT has jurisdiction for: – In transit operations between destination points, including read justing and securing the load. – Proper handling of hazardous materials during loading and unload ing vehicles and rail cars according to the Hazardous Materials Regulations (49 CFR 171-180). • OSHA has jurisdiction for: – Actions associated with loading and unloading the vehicle or rai lcar at destination points where DOT does not address a safety or health hazard. – Response to hazardous waste emergencies.
    6. 6. Overall objectives of today’s training presentation Will focus primarily on DOT training but will also encompass the main requirements of OSHA & EPA training requirements regarding the handling and transporting of hazardous materials Help to prevent unplanned releases and accidents involving the hazardous materials transported by this operation Provide information regarding the hazards of the chemicals/hazardous materials that you may be exposed in your workplace.
    7. 7. Scope of training You should: Be familiar with the general provisions of the Hazardous materials regulations (HMR) part 172, subpart H (formerly HM126F) Be able to recognize and identify the hazardous materials as they apply to your job function Have knowledge of emergency response information, self protection measures, and accident prevention methods and procedures
    8. 8. DOT required Haz Mat employee training shall include General awareness/familiarization training Function-specific training Safety training Driver training • Specific cargo tank training Security awareness
    9. 9. Hazardous materials covered in this presentation Propane Diesel Gasoline Fuel oil ( #2, #6) Kerosene
    10. 10. AREAS THAT WE WILL COVER RELEVANT TO THESE PRODUCTS ARE: Hazardous materials table North American Emergency guide book (guide sheet 128) Shipping papers Placarding Highway carrier requirements Emergency response procedures
    11. 11. Areas we will not cover today Packaging Labeling Transport by Air Transport by Rail Hazardous materials other than propane,oil, diesel, kerosene *These are topics that are included in the requirements but do not apply to your operation
    12. 12. HAZMAT EMPLOYEE (49 CFR 171.8) A HAZMAT employee is a person employed by a HAZMAT employer and who, in the course of employment, directly affects hazardous materials transportation safety. This term includes owneroperators of a motor vehicle that transports hazardous materials in commerce.
    13. 13. Hazmat Employee (includes owners) Loads, unloads, or handles hazardous materials Manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums or packaging as qualified for use in the transportation of hazardous materials Prepares hazardous materials for transportation Is responsible for safety of transporting hazardous materials Operates a vehicle used to transport hazardous materials
    14. 14. HMR divides responsibility in three categories The shipper The carrier The driver
    15. 15. The shipper (owner, driver, dispatcher, fleet manager, office) Person or company sending the hazmat from one place to another: Must assign proper shipping name, hazard class, identification numbers, correct type of packaging, correct label and marking on placards, correct placards Properly packages the hazmat Prepares shipping papers Certifies on the shipping papers that they have prepared shipment properly
    16. 16. The carrier (driver, fleet manager, company owner) Transports shipment to destination Ensures that product has been correctly named, labeled and marked for shipment Reports any accidents or incidents to the proper government agency
    17. 17. The driver Ensures that shipper has properly identified, marked and labeled product Must refuse leaking shipments Attaches appropriate placards Delivers products safely & obeys all rules and requirements Keeps shipping papers in proper place
    18. 18. General Awareness Must be familiar with the requirements of HM training requirements Hazard communication training • Must be able to recognize HM • Must know hazards of chemical to which you may be exposed (hazard classes) • Must know what to do in the event of an emergency or unplanned release
    19. 19. Function-specific training Must be familiar with the standards as they apply to your specific job These will vary depending on the individual’s specific job function
    20. 20. Safety training Must include: Emergency response information required by subpart G of part 172 Measures to protect the employee from the hazards associated with the HazMat to which they may be exposed in the work place, including specific measures the hazmat employer has implemented to protect employees from exposure Methods & procedures for avoiding accidents involving hazardous materials
    21. 21. Driver training Training must include the following subjects: Pre-trip inspection Use of vehicle controls and equipment, including operation of emergency equipment Operation of vehicle • Turning, backing,braking, parking,handling, effects of braking, dangers of maneuvering through curves, effects of speed, dangers of weather & road conditions, and high center of gravity Procedures for maneuvering tunnels, bridges and railroad crossings Requirements pertaining to attendance of vehicles, parking, smoking routing and incident reporting Loading and unloading procedures Packaging and securing load
    22. 22. Operators of Cargo Tanks Training for cargo tank drivers must include: Operation of emergency control features of the cargo tank Special handling characteristics • High center of gravity, fluid-load subject to surge, effects of fluidload surge on braking, characteristic differences in stability among baffled, un-baffled and multi-compartmented tanks, effects of partial loads on vehicle stability Loading & unloading procedures Properties and hazards of the materials transported Retest and inspection requirements for cargo tanks.
    23. 23. QUESTIONS
    25. 25. Part Two General Familiarization
    26. 26. Hazardous Materials “Materials that are capable of posing an unreasonable risk to health, safety, & property when transported in commerce.” A material is considered to hazardous if it: •Meets one or more hazard class definitions •Is a hazardous substance, hazardous waste, marine pollutant, or elevated-temperature material.
    27. 27. Hazardous Materials Table Lists and classifies those materials which the DOT has designated as hazardous materials for purposes of transportation and prescribes the requirements for shipping papers, package marking, labeling, and transport vehicle placarding applicable to the shipment and transportation of those hazardous materials.
    28. 28. The Hazardous Materials Table
    29. 29. The Hazardous Materials Table Lists materials alphabetically by proper shipping name Consists of 10 major headings: • Symbols • HM descriptions & proper shipping names • Hazard class or division • Identification numbers • Packaging group assigned to the material • Label codes • Special provisions • Packaging • Quantity limitations • Vessel Stowage
    30. 30. Symbols + - “Fixes”(means you can’t change it) the proper shipping name, hazard class or division and packing group in columns 2, 3 &5 A – means that the material is only regulated if offered for and/or transported by air, unless the material is a hazardous substance or hazardous waste. In that case, it’s regulated in all modes of transportation * see definitions D- Identifies proper shipping names describing materials for domestic transportation. G-identifies n.o.s. and generic proper shipping names that require the addition of one or more technical names I-identifies proper shipping names describing materials for international transportation W-means material is regulated only if transported by water unless the material is a hazardous substance or hazardous waste
    31. 31. Nine hazard classes Class 1 - Explosives Class 2 - Gases Class 3 - Flammable liquids Class 4 - Flammable solids Class 5 - Oxidizing substances and Organic Peroxides Class 6 - Poisons/Toxic Materials Class 7 - Radioactive materials Class 8 - Corrosive materials Class 9 - Miscellaneous hazardous materials
    32. 32. Definitions of Hazard classes Review handout #1
    33. 33. Products that may be carried by your company Propane • Class 2 #2 Fuel, diesel, kerosene, gasoline • Class 3
    34. 34. Activity Look up propane or fuel oil in the table
    35. 35. Packing groups PG I - great danger PG II - medium danger PG III - minor
    36. 36. Shipping papers Must include: Proper shipping name Hazard class Identification number Total quantity of materials being shipped
    37. 37. When transporting Empty Cargo Tanks Shipping papers are still required if a cargo tank has been emptied, but not cleaned of the hazardous residue. (For Propane dealers) When transporting ASME tanks with a capacity of 125 gallons or greater to or from a customer’s location, they must not contain more than 5% propane during transport.
    38. 38. Shipping papers May be in any form or format as long as it contains the information required by the HMR in the correct sequence Must contain basic description & any additional descriptions or entries Must be legible & printed in English Must accurately communicate the hazards of the materials being transported Most must be certified but certification is not required for materials transported by cargo tank
    39. 39. Shipping papers Must be readily available & visible to a person entering the driver’s compartment Must be clearly distinguishable Must be within immediate reach of the driver while restrained by lap belt When the driver is not in vehicle must be in holder on inside of door or on driver’s seat
    40. 40. 24-hour Emergency Response number Required on all shipping papers Must be monitored at all times while the material is in transportation, including storage incidental to transportation Contact person must be capable of providing emergency response & incident mitigation information immediately, upon request
    41. 41. Emergency Response Information The shipper must also provide emergency response information for each hazardous material listed on the shipping paper
    42. 42. Emergency Response Information Information about hazardous materials & the necessary immediate precautions & actions to take in the event of a spill or leak are required Must carry in the same manner as the shipping papers
    43. 43. North American Emergency Guidebook-Guide Sheet 128
    44. 44. Placards There are two placarding tables: When determining which placards must be used and what options are available, both placarding tables must be considered
    45. 45. Placards Must clearly communicate the hazard of the material being transported Must have no visual competition Must be readily visible from the direction it faces Be on all four sides of vehicle (each side and each end) placed so words are level and read from left to right Must be located clear of appurtenances and devices, away from dirt and water & at least three inches away from any other markings Words and/or numbers must be displayed horizontally
    46. 46. Placard modifications The word “gasoline” may be used in place of the word “flammable” on cargo tank transporting gasoline Fuel oil (in cargo tank) may be used in place of word “combustible”
    47. 47. Placard Placarding is responsibility of shipper and carrier (that includes driver). If the required placard is missing, or damaged, no matter what the reason, the shipment must not be transported.
    48. 48. QUESTIONS
    49. 49. End Part Two 10 Minute Break
    50. 50. Part Three Carriage by Highway
    51. 51. HMR, part 177 “Carriage by Public Highway” Requires motor carriers to train employees in the prescribed regulations Additional specific training is required for operators of cargo tanks or vehicles with a portable tank with capacity of 1,000 gallons or more
    52. 52. Motor Carriers Must also comply with the Federal Motor Carrier Safety Regulations (FMCSR) & refer to driver qualifications, hours of service, equipment standards and operational requirements. US DOT reps may inspect all motor carrier records, equipment, packaging & containers -- that may affect the safe transportation of hazardous materials
    53. 53. Loading and unloading (HMR 177.834) Attendance requirements • A cargo tank must be attended by a qualified person at all times when it is being loaded • The person who is responsible for loading the cargo tank is also responsible for ensuring that is so attended
    54. 54. Loading & Unloading A person “ attends” the loading or unloading of a cargo tank if, throughout the process: He/she is awake/alert Has unobstructed view of the cargo tank Is within 25 feet of the cargo tank Knows the hazards of the material
    55. 55. Safety Measures No smoking on or near vehicle No spark producing tools Use caution with tools so as not to damage packages, containers, or their closures Do not load flammable materials in a cargo space that has a heater unit
    56. 56. Driver Training/Cargo Tank Trucks
    57. 57. Pre-Trip Inspection “No motor vehicle shall be driven unless the driver thereof shall have satisfied himself that the following parts & accessories are in good working order, nor shall any driver fail to use or make use of such parts and accessories.” (FMCSR part 392.7)
    58. 58. Pre-Trip Inspection Critical inspection items include: • Service brakes • Parking brake • Steering mechanism • Lighting devices & reflectors • Tires • Horn • Windshield • Rear-vision mirror or mirrors • Coupling devices
    59. 59. 7- Step Pre-Trip Inspection procedure Vehicle overview Check engine compartment Start engine & inspect inside the cab Turn off engine & check lights Do walk around inspection Check signal lights Start engine & check brake system
    60. 60. Product weight Prior to loading vehicle, you must know: Amount the liquid will expand Weight of liquid per gallon Legal weight limits
    61. 61. Outage The space you leave for expansion is called Outage You must know the outage requirements of each product you haul
    62. 62. Cargo tanks High center of gravity subject to “surge” Prone to roll over on curves, ramps and during evasive movements
    63. 63. 3 Types of tanks Bulkhead Baffled Un-baffled or “smooth bore”
    64. 64. Bulkheads: Solid steel divider within the tank which creates separate compartments
    65. 65. Baffles Dividers with holes in them, designed to slow down the front-to-back surge. They do not have much effect on side-to-side surge
    66. 66. SURGE: The movement of the liquid from the front to the back, and from side to side. Determined by two major factors: Amount of liquid in the tank Design of the tank
    67. 67. Countermeasures for dealing with Surge Maintain 12 to 15 second eye lead time Always slow down before entering curves - posted limit is for cars not tankers Accelerate gently through the curve Avoid sudden stops whenever possible by maintaining a good cushion of safety around the vehicle.
    68. 68. Three factors that can cause a skid Oversteering Overbraking Overacceleration
    69. 69. Emergency maneuvers It is almost always better to steer to avoid an emergency than to brake to avoid one Don’t brake while making an emergency turning maneuver. If you must brake, use stab or controlled braking When using stab braking, release the brakes as soon as the wheels lock up, and then apply the brakes hard again If the steering tires lock up, you will continue straight regardless of how you turn the wheel If you must leave the roadway, slow to 20 mph, if possible, before applying brakes
    70. 70. QUESTIONS
    71. 71. Part Four Spill prevention and emergency response procedures & action plans
    72. 72. Objectives for this section Review OSHA HAZWOPPER requirements Review the emergency operating procedure requirements Review some emergency operating procedures Review spill prevention measures
    73. 73. OSHA first responder awareness level First responders are individuals who are likely to witness or discover a hazardous material release & have: • an understanding or what hazardous chemicals are & risk associated with them; • an understanding of potential outcomes of HM emergency • the ability to identify the hazardous materials • understanding the role of first responder in the emergency response • plan, including site security & control • ability to realize need for additional resources & make appropriate • notification to communication center
    74. 74. First Responders Operations level Knowledge of basic hazard & risk assessment techniques Know how to select & use proper personal protective equipment provided Has understanding of basic hazardous materials terms Knows how to perform basic control, containment and/or confinement (dam, dike, divert) Knows basic decontamination procedures Understands relevant SOP & termination procedures
    75. 75. Basic terms Flammable liquid-any liquid that has a flash point 140F or less Flash point-temperature where the liquid will ignite, detonate, explode
    76. 76. North American Emergency guidebook Contains information on hazardous materials Accepted by emergency response information Driver should have individual guide sheets or should know which guide sheets apply to the product being carried In the event of accident, if possible take guide sheet & shipping papers and get away from vehicle Provide ER info to first responders
    77. 77. North American emergency guide sheets provide info in the following areas: Potential hazards • Fire or explosion Emergency response • Fire • Health • Public safety • Spill or leak • First aid • Protective clothing • Evacuation • Fire
    78. 78. North American emergency guidebook-guide sheets 128 (Petroleum Oil) & 115 ( Propane)
    79. 79. Potential hazards of petroleum products Guide Sheet 128 <>FIRE OR EXPLOSION· HIGHLY FLAMMABLE: Will be easily ignited by heat, sparks or flames. · Vapors may form explosive mixtures with air.· Vapors may travel to source of ignition and flash back. · Most vapors are heavier than air. They will spread along ground and collect in low or confined areas (sewers, basements, tanks). · Vapor explosion hazard indoors, outdoors or in sewers. · Those substances designated with a "P" may polymerize explosively when heated or involved in a fire. · Runoff to sewer may create fire or explosion hazard. · Containers may explode when heated. · Many liquids are lighter than water. · Substance may be transported hot.
    80. 80. Potential hazards of Propane-Guide Sheet 115 <>FIRE OR EXPLOSION· EXTREMELY FLAMMABLE. · Will be easily ignited by heat, sparks or flames. · Will form explosive mixtures with air. · Vapors from liquefied gas are initially heavier than air and spread along ground. · Vapors may travel to source of ignition and flash back. · Containers may explode when heated. · Ruptured cylinders may rocket.
    81. 81. Health Hazards of petroleum products
    82. 82. Protective measures
    83. 83. Emergency Operating Procedure requirements A comprehensive written emergency operating procedure must be developed for all transfer operations and hazmat employees who perform unloading functions must be trained in its provisions. The emergency operating procedure must be prominently displayed in or on the cargo tank motor vehicle
    84. 84. Emergency responses for leaks during transit  If the problem is before the nozzle, then SHUT OFF THE NOZZLE.  If the problem is with the nozzle, then PUSH THE STOP BUTTON at the meter.  If the problem is with the tank, then USE CONTAINMENT MEASURES TO STOP OR SLOW THE LEAK, THEN CALL FOR HELP.  If the truck is on the roadway, try and pull OUT OF THE FLOW OF TRAFFIC but DO NOT drive beyond the nearest point at which safe removal of the fuel can be made.  Warn nearby person of fire hazard. Extinguish nearby open flames. DO NOT SMOKE!  Report the spill to your company emergency response coordinator
    85. 85. Emergency response procedures in transit If possible: Dam, Dike or Divert spilled product, keep it away from storm or sewer drains, catch basins and waterways. Contain product using booms, pigs, absorbent pads or gravel/soil embankments. Secure site until remediation and emergency response personnel arrive on the scene. However, never take action unless you have been properly trained (awareness level and operators level) and directed by your employer to do so.
    86. 86. If a spill occurs during delivery or service call Shut off the supply Look around for sump pumps, drains or holes ,or cracks in floors and foundation-keep oil away from these areas Contain spill by using oil pads, booms or speedy dry Use plugs or patch on tanks if possible Create a vacuum in tank by using a fill cap or plastic bag and placing over fill. Say as little as possible to homeowners, never admit liability!
    87. 87. REPORT ALL SPILLS If spill happens during normal business hours: report to office If after hours, call SPLASH hotline direct
    88. 88. Be prepared to tell them Extent of spill-quantity Location of the spill • Address • Inside home, outside home, on the road When it happened If in the home, has the homeowner been notified If on the road, have any emergency responders arrived on the scene Is the product contained or not
    89. 89. Spill prevention while loading or unloading ( delivering product)
    90. 90. Most common spill claims Tank over-pressurization • blocked or partially blocked vent • pumping too fast for vent pipe size Misdelivery: • disconnected fill pipe • defective tank • wrong address Leaking hoses
    91. 91. Recommended spill prevention measures •Always employ No Whistle-No fill policy •Double check address & location of fill •NEVER LEAVE THE FILL PIPE during delivery! Stay alert. •Pre-inspect new customers whenever possible •Use reasonable pumping rates-no greater than 70gpm •Check hoses for wear on regular basis •Pull hose from shoulder, never drag nozzle on ground •If you suspect anything is wrong. STOP the delivery and call dispatch
    92. 92. Safety really is No accident! Famous last words: “It’s just common sense” “That could never happen to me” “It’s not my fault…the other guy should have removed that disconnected fill” “But I had the right of way” “I’ve been doing it this way for years!”
    93. 93. Any final questions?
    94. 94. Thank you!