Hazardous Materials Regulations Training Requirements

All hazmat shipments leaving your facility must comply with the DOT Hazardous Materials Regulations (49 CFR). Training is mandatory for managers and employees preparing hazardous materials for transportation. The DOT's hazmat rules are strict. For hazmat training violations, the minimum civil penalty is $582 per employee per day.

HMR mandates training requirements for individuals who prepare hazardous materials for shipment or who transport hazardous materials in commerce. The regulations aim to ensure that each hazmat employee is familiar with HMR, can recognize and identify hazardous materials, understands the specific HMR requirements applicable to their duties, and has knowledge of emergency response, protective measures, and accident prevention methods. HMR requires all hazmat employees to be trained, including hazmat employers, with direct supervision of hazmat transportation functions.

• Training must be completed within 90 days of the first day of employment or job role change.
• Until training is completed, a hazmat employee must be directly supervised by a person who has been trained.
• Every hazmat employee must receive recurring training at least once every three years.
• Each hazmat employee must be screened upon completion of the training.
• The hazmat employer is responsible for maintaining detailed training records for each hazmat employee that meets the DOT's strict formatting requirements. These records must be maintained for the three-year training cycle. At the same time, the hazmat employee is employed for 90 days after the employee leaves employment. The employer must make the training records available for audit and review by regulatory authorities upon request.

What training is required?

The hazmat employer determines the level and details of training based on an employee's job duties. However, the DOT requires certain categories of training.

1. General Training: At a minimum, all hazmat employees should receive a general understanding of the entire hazmat transportation program. Hence, they know how their jobs fit into the system.
2. Role-Specific Training: All hazmat employees must also receive training on any job-specific function concerning hazmat regulations.
3. Safety Training: Individuals who handle or are potentially exposed to hazardous materials during the transportation cycle (e.g., drivers, shippers, loading dock workers, and warehouse workers) should be trained in safe handling and emergency response procedures applicable to the hazards to which they may be exposed.
4. Security Awareness Training: All hazmat employees must be trained to recognize and protect against potential terrorist threats involving shipments of hazardous materials.

In some cases, you may also need in-depth security training, depending on the nature of your business and the specific job functions they perform.

Determine Your Hazardous Materials Employees

The safe transportation of hazardous materials depends on the proper preparation of the material for shipment and the safe handling of the material while it is being transported. Every hazmat employee should be aware of the hazards of such materials, their potential to cause incidents and accidents, and how they should be prepared and transported safely.

Each "hazardous materials employer" must train all "hazardous materials employees." A hazmat employee is anyone who, in the course of employment, directly affects the safety of transporting hazardous materials. Examples a hazmat employees include a person who:

• Determines the hazard class of a hazardous material.
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• Design, select, purchase, or fill packages (includes designers and product engineers).
• Determines if a package can be reused, is empty, or needs reconditioning (e.g., tank cars, cargo tanks, and drums).
• Fills or loads a package of hazardous materials.
• Secures a seal on a package or container filled with hazardous materials.
• Mark a package to indicate that it contains a hazardous material.
• Label a package to indicate that it contains a hazardous material.
• Prepare a hazmat shipping document.
• Provides and maintains hazardous materials emergency response information.
• Review a hazmat shipping document to verify HMR compliance.
• For individuals importing hazardous material into the U.S., provide the shipper with information about the HMR requirements for shipping the material while in the U.S.
• It certifies that a hazardous material is in a suitable condition for transport per the requirements of the HMR.
• Locks and braces a package of hazardous materials in a cargo container or transport vehicle.
• Place warning signs, lock wheels, and put brakes on tank carts for loading or unloading with the locks open.
• Segregates a package of hazardous materials into an incompatible cargo container or cargo transport vehicle.
• Selects, provides, or pins signs to a cargo container or transport vehicle to indicate that it is transporting hazardous materials.
• Loading or unloading hazardous materials for transportation.
• Tests, refurbishes, or repairs hazmat packaging.
• Operates a vehicle used to transport hazardous materials.

Anyone who directly supervises those performing the above activities should also be trained. In addition, hazmat employers must also ensure that anyone performing any regulated function on their behalf, such as a contractor, has received full training before beginning their job.

Advantages of Computer-Based Training

There are many different options for providing hazmat training to your employees. Here are some advantages of computer-based training with your own Learning Management System (LMS) for hazardous materials.

• Possibility to customize the material according to your exact needs.
• It provides standardized training, ensuring a consistent message.
• It decreases the time employees are away from the office and away from manufacturing jobs.
• Allows for quick updates for rapidly changing material.
• Training is more accessible to a wider audience – it's easy to train large numbers quickly.
• Training is more convenient for employees – available 24/7, anytime, anywhere.
• No travel expenses.
• Employees can proceed at their own pace.
• Easy to enroll employees in training.
• Online tests ensure instant results for those who pass the course.
• Online recordkeeping complies with HMR requirements and audits.

Self-Learning Solutions is available (visit www.hazmatauthority.com) to discuss your hazmat training needs. If you have any questions, please contact us at 1-608-690-3858 or servicio@slstechpr.com. Thank you!