Page 82 - Occupational Health & Safety, June 2017

TRANSPORTATION SAFETY
Key Requirements for Employees Transporting Hazmats
Like OSHA and EPA chemical safety trainings, DOT training helps hazmat employees to recognize and identify hazardous materials and learn how their functions ensure that those materials can be transported safely.
BY KAREN D. HAMEL
Between OSHA and EPA’s training require- ments, employees who handle hazardous materials in their workplace should be very familiar with the hazards presented by any
of the chemicals they work with daily. But when haz- ardous materials leave the facility in the form of a fin- ished product, OSHA and EPA training is not enough.
The Pipeline and Hazardous Materials Safety Administration (PHMSA), which is part of the U.S. Department of Transportation (DOT), requires ev- ery person who is involved in the transportation of hazardous materials in commerce to receive specific training to understand how their actions affect trans- portation safety. Any facility that offers a hazardous material for transportation is a “hazmat employer” and must properly train its “hazmat employees.”
Hazmat Employees
Hazmat employee training isn’t just for commercial drivers or facility representatives who sign manifests. While DOT’s definition of “hazmat employee” certain- ly does include those individuals, many more require hazmat employee training, including employees who:
■ load, unload, or handle hazardous materials;
■ test, recondition, repair, modify, mark, or oth- erwise represent containers or packages that qualify for transporting hazardous materials;
■ prepare or offer hazardous materials for trans- portation;
■ design, manufacture, or test packaging used to 78 Occupational Health & Safety | JUNE 2017
transport hazardous materials; or
■ are otherwise responsible for the safety of
transporting hazardous materials.
Unlike some regulations that exempt small em-
ployers, the training requirements for hazmat em- ployees apply to every facility that is involved with the shipment of hazardous materials, even if they are self- employed. (49 CFR 171.8)
Like OSHA and EPA chemical safety trainings, DOT training helps hazmat employees to recognize and identify hazardous materials and learn how their functions ensure that those materials can be transport- ed safely. Training includes several different aspects and must be completed within 90 days of employment or on the first day of a change in job function.
Employees must be tested at the completion of training and be able to demonstrate their knowl- edge. Until an employee can be trained, they must work under direct supervision of a person who has been trained.
General Awareness Training
All hazmat employees must receive general awareness training. This training is similar to OSHA’s hazard communication training and in many cases can be combined with hazard communication training, as long as the required DOT elements are covered. Gen- eral awareness training is designed to help employees recognize, identify, and classify hazardous materials. It also teaches employees the general requirements of
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