Page 84 - Occupational Health & Safety, June 2017

TRANSPORTATION SAFETY
event of a security breach.
Retraining and Recordkeeping
Every three years, hazmat employees must be retrained. The training should not be a brief refresher or solely an update; it must be compliant with current rules and include all of the same elements that were included in the original training. [49 CFR 172.704(c)(2)] Additionally, if a hazmat employee’s job duties change, he or she must receive function-specific training and any other required training prior to performing those new duties without supervision.
DOT takes this retraining very seriously. Like training for a new hazmat employee, recurrent trainings must include testing follow- ing the completion of the training. And employees who are not retrained within three years may not perform hazmat employee functions until they are retrained.
When DOT adds or revises rules that affect a hazmat employ- ee’s functions, they must receive retraining “prior to performance of a function affected by the new or revised rule.” This training may not be delayed until the employee’s three-year training cycle is due.
Employers are responsible for keeping training records for each hazmat employee. Complete records include the employee’s name, the date of the most recent training or retraining, a description or copy of the training materials used, and the name and address of the person providing the training. Each hazmat employee must
have a document certifying that he or she has been trained and tested as required. Training records must be kept for the entire duration of the three-year training cycle and for 90 days after an employee leaves.
Just as OSHA and EPA regulations protect employees from the dangers of hazardous chemicals in the workplace, DOT’s hazmat employee rules protect transporters and communities when haz- ardous materials are on the road, in the water, or in the sky. Identi- fying hazmat employees and providing them with the proper train- ing helps to ensure that hazardous materials are kept safe at each step in the process.
Karen D. Hamel, CSP, WACH, is a regulatory compliance profession- al, trainer, and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA, and DOT regulations and has had more than 100 ar- ticles published on a variety of EHS topics. She is a Certified Safety Professional (CSP,) Walkway Auditor Certificate Holder (WACH,) Community Emergency Response Team (CERT) trainer, hazmat technician, serves on the Blair County, PA LEPC, and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS® (468-4647) or by email to karenh@newpig.com.
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