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The regulations of the PHMSA/USDOT at 49 CFR 172, Subpart H require a HazMat Employer to identify and train all of their HazMat Employees initially (within 90 days of hire) and at least once every three years thereafter. Training content must meet the requirements of 49 CFR 172.704. This presentation is a slightly updated and revised version of one I uploaded in 2012. It's purpose is to assist you in determining if you are a HazMat Employer (you are), if you employ any HazMat Employees (you do), and what training the regulations require.
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@DanielsTraining 1
THE IDENTIFICATION AND TRAINING OF HAZMAT EMPLOYEESPursuant to the regulations of the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the USDOT
Identification & Training of HazMat Employees
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PRESENTED TO:
Identification & Training of HazMat Employees
The 2013 Michigan Safety
Conference
Thanks for the opportunity!
@DanielsTraining 3
PRESENTED BY:
Identification & Training of HazMat Employees
Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com
A different kind of training.
@DanielsTraining
A Question Before We Start…
•Have you identified, trained, and tested all the HazMat Employees at your facility?
Identification & Training of HazMat Employees 4
Leading source of USDOT violations/fines
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WHAT IS A HAZARDOUS MATERIAL (HAZMAT)?It all begins with the PHMSA/USDOT’s definition of a hazardous material.
Identification & Training of HazMat Employees
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What is a Hazardous Material?
• Defined @ 49 CFR 171.8, as capable of posing an unreasonable risk to health, safety, and property when transported in commerce.
Identification & Training of HazMat Employees
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Hazardous Materials Include:
• Technical Name listed in Hazardous Materials Table (49 CFR 172.101).
• Exhibits the characteristic of a hazard class or division (49 CFR 173.2).
• Hazardous Substance (49 CFR 171.8).• Hazardous Waste (49 CFR 171.3).• Marine Pollutant (49 CFR 171.4).• Elevated Temperature Material (49 CFR 171.8).
Identification & Training of HazMat Employees
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Hazardous Materials are Common
Identification & Training of HazMat Employees
From LQG or SQG
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WHO OR WHAT IS A HAZMAT EMPLOYER?If you meet the definition of a HazMat Employer at 49 CFR 171.8, then you are responsible for identifying and training your HazMat Employees.
Identification & Training of HazMat Employees
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You are a HazMat Employer if…(1.0)
• You employ at least one HazMat Employee.
and…
1. Transport a hazardous material in commerce.
Identification & Training of HazMat Employees
Or….
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You are a HazMat Employer if…(2.0)
• You employ at least one HazMat Employee,
and…
2. Cause a hazardous material to be transported in commerce.
Identification & Training of HazMat Employees
Or….
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Packaging Manufacturers are Also HazMat Employers (3.0)
3. Design, manufacture, fabricate, inspect, mark, maintain, recondition, repair or test a hazardous material package or package component.
Identification & Training of HazMat Employees
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A HazMat Employer Includes
• Any department, agency, or instrumentality of the US.
• A state or political subdivision of a state.• An Indian tribe.• An owner/operator of a motor vehicle.
Identification & Training of HazMat Employees
If they offer a HazMat for transportation or transport in commerce
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WHAT IS A HAZMAT EMPLOYEE?Which of your employees are HazMat Employees?
Identification & Training of HazMat Employees
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Defined at 49 CFR 171.8Hazmat employee means: (1) A person who is:
(i) Employed on a full-time, part time, or temporary basis by a hazmat employer and who in the course of such full time, part time or temporary employment directly affects hazardous materials transportation safety;
(ii) Self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft) transporting hazardous materials in commerce who in the course of such self-employment directly affects hazardous materials transportation safety;
(iii) A railroad signalman; or
(iv) A railroad maintenance-of-way employee.
(2) This term includes an individual, employed on a full time, part time, or temporary basis by a hazmat employer, or who is self-employed, who during the course of employment:
(i) Loads, unloads, or handles hazardous materials;
(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.
(iii) Prepares hazardous materials for transportation;
(iv) Is responsible for safety of transporting hazardous materials;
(v) Operates a vehicle used to transport hazardous materials.
Identification & Training of HazMat Employees
HUH?!?
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A Breakdown of the Definition (1.0)
• Employed full-time, part-time, temporary, or self-employed.
and…• Whose job directly affects hazardous material transportation safety.
• Also includes…• Railroad signalman.• Railroad maintenance-of-way employee.
Identification & Training of HazMat Employees
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A Breakdown of the Definition (2.0)
• HazMat Employee also includes full-time, part-time, temporary, or self-employed who…• Loads, unloads, or handles hazardous materials;• Involved in any phase of manufacture of HazMat packaging.
• Prepares hazardous materials for transportation;• Is responsible for safety of transporting hazardous materials;
• Operates a vehicle used to transport hazardous materials.
Identification & Training of HazMat Employees
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WHAT DOES A HAZMAT EMPLOYEE DO?The regulatory definition is a start, but it also helps to have a description – with pictures! – of the job duties of a HazMat Employee.
Identification & Training of HazMat Employees
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A HazMat Employee hasPre-Transportation Responsibilities
• Determines the hazard class of a hazardous material.
• Selects a hazardous material’s packaging.
• For imports, provides the shipper with information about the regulations.
Identification & Training of HazMat Employees
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A HazMat EmployeeFills & Closes HazMat Packagings
• Fills or loads a hazardous materials packaging.
• Secures a closure on a hazardous materials packaging.
Identification & Training of HazMat Employees
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A HazMat EmployeePrepares HazMat Packagings
• Marks & labels package to indicate that it contains a hazardous material.
• Ensures a package is in proper condition for transportation.
Identification & Training of HazMat Employees
HazMat Labels
Markings
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A HazMat EmployeeAssists the Vehicle Driver
• Loads or unloads HazMat for transportation.
• Secures & segregates a HazMat package in a vehicle.
• Selects, provides, or affixes placards.
Identification & Training of HazMat Employees
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A HazMat EmployeeLoads or Unloads HazMat
Identification & Training of HazMat Employees
This includes the loading or unloading of bulk quantities
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A HazMat Employee Assists in Transportation by Rail
• Places warning signs, blocks wheels, and sets brakes on tank cars placed for loading or unloading with closures open.
Identification & Training of HazMat Employees
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A HazMat EmployeeProvides Oversight and Supervision
• Certifies a hazardous material is ready for transportation.
• Supervises HazMat Employees.
• Is responsible for the safe transportation of hazardous materials.
Identification & Training of HazMat Employees
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A HazMat EmployeeHandles Shipping Papers• Prepares a hazardous materials shipping paper.
• Provides and maintains emergency response information.
• Reviews a hazardous materials shipping paper to verify compliance with the regulations.
Identification & Training of HazMat Employees
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Including a Uniform Hazardous Waste Manifest• Prepares a uniform hazardous waste manifest.
• Provides and maintains emergency response information.
• Reviews a uniform hazardous waste manifest to verify compliance with the regulations.
Identification & Training of HazMat Employees
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A HazMat EmployeeManufactures, etc. Packages• Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs or tests a package or package component.
Identification & Training of HazMat Employees
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A HazMat EmployeeOperates a Vehicle Used to Transport a Hazardous Material
Identification & Training of HazMat Employees
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HOW MUST I TRAIN MY HAZMAT EMPLOYEES?Once you’ve identified your HazMat Employees, you as the HazMat Employer must ensure they are trained and tested per the requirements of 49 CFR 172, Subpart H.
Identification & Training of HazMat Employees
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Training Requirements of49 CFR 172, Subpart H
General Awareness/Familiarization
Function-Specific Responsibilities
Safety & Emergency Response
Security General Awareness
In-Depth Security
Identification & Training of HazMat Employees
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Training Requirements of49 CFR 177.816
Professional Driving Skills
Identification & Training of HazMat Employees
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• Familiarity with the general requirements of the HMR.
• Enable a HazMat Employee to recognize and identify hazardous materials.
Identification & Training of HazMat Employees
General Awareness/Familiarization
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• A detailed understanding of the specific job function(s) of the HazMat Employee.
Identification & Training of HazMat Employees
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• The hazards presented by hazardous materials.
• Safe handling.• Emergency response.• How to avoid accidents.
Identification & Training of HazMat Employees
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• Security risks associated with HazMat transportation.
• Methods to enhance security.
• How to recognize and respond to possible security threats.
Identification & Training of HazMat Employees
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• Applicability determined by type and amount of hazardous materials shipped.
• Refer to 49 CFR 172.800(b).
Identification & Training of HazMat Employees
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• Company security objectives.• Specific security procedures.• Employee responsibilities.• Organizational security structure.
and…• Actions to take in the event of a security breach.
Identification & Training of HazMat Employees
Will also require the HazMat Security Plan
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When Train and How Often?
Initial
• Within 90 days of employment or new job assignment.
• Supervised by trained and knowledgeable personnel in that time.
Recurrent
• Full training at least once every 3 years.
Identification & Training of HazMat Employees 39
@DanielsTraining
Training Requirements
• HazMat Employee must be tested as part of training.
• HazMat Employer ensures training and testing is adequate and appropriate.
• No training or experience requirement for trainer.
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HazMat Training Documentation
• Specific requirements at 49 CFR 172.704(d).
• Retain training record for current employees until facility closure.
• At least 90 days from HazMat Employee’s last day.
Identification & Training of HazMat Employees
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For More Information
1. What You Should Know: A Guide To Developing A Hazardous Materials Training Program
2. Does Your HazMat Training Measure Up?
3. US DOT website: HazMat Employee Training Requirements.
Identification & Training of HazMat Employees
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I provide:Annual RCRA Training for Hazardous Waste Personnel.AndTriennial HazMat Employee Training.
Public Seminars, Onsite, Webinars…
ID & Management of Universal Waste in Michigan
Daniels Training Services815.821.1550Info@DanielsTraining.comwww.DanielsTraining.com
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