Page 83 - Occupational Health & Safety, June 2017
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DOT’s hazardous materials regulations. This includes skills such as using the hazardous materials table, how to mark and label pack- ages, and how to prepare shipping papers. (49 CFR 172.704)
Function-Specific Training
Because hazmat employees perform a diverse set of tasks before and during transportation, function-specific training is also re- quired. This training provides targeted education on the specific function(s) that a hazmat employee will perform. For example, if a hazmat employee is filling packages, function-specific training may include how to close the package properly so that it will not leak or fail during shipment. Function-specific training for anyone sign- ing manifests would include choosing a proper shipping name and other procedures specific to that task.
For some employees, function-specific training may include tasks required by International Maritime Dangerous Goods (IMDG) Codes, International Civil Aviation Organization (ICAO) Technical Instructions, or other procedures to fill the requirements specific to the mode of transportation or ultimate destination.
Safety Training
Like general awareness training, safety training that meets OSHA and EPA regulations may be used to satisfy the safety training re- quirements for a hazmat employee if the DOT requirements are also met. Training must specifically cover situations that a hazmat
employee may encounter while handling a hazardous material. Some of the topics that may be applicable are safe handling, bulk delivery, and closing containers when they are not in use. Hazmat employees also should be aware of emergency action plans, spill response procedures, fire prevention plans, and any other proce- dures that are in place to help prevent injury while preparing or
transporting a hazardous material.
Security Awareness Training
Preparing hazardous materials for shipment and transporting them can present security risks. Hazardous materials can also pres- ent health, safety, and property risks when they are transported.
All hazmat employees must be aware of the security plan and be able to identify these types of risks before or during transporta- tion. They also need to be trained to respond to possible security threats, which could include threats to a company or unexpected circumstances during transportation.
Hazmat employees who are responsible for implementing a security plan and those who perform regulated functions within the security plan must receive in-depth security training. The con- tent will be specific to the facility and will address specific risk and threats that may be encountered.
Training must include a detailed understanding of the security plan, including objectives, organizational security structure, pro- cedures, employee responsibilities, and actions to be taken in the
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