A presentation from the 2012 Michigan Safety Conference and the 2012 Iowa- Illinois Safety Council Professional Development Conference. It contains an explanation of the difference between HAZWOPER and HazMat Transportation, a description of the terms: hazardous material, HazMat Employer, and HazMat Employee; and the training requirements for HazMat Employees.

1. HazMat Employee Training Requirements @DanielsTraining 1
HAZMAT EMPLOYEE
TRAINING
REQUIREMENTS
Pursuant to the US DOT regulations at
49 CFR 172, Subpart H.

2. HazMat Employee Training Requirements @DanielsTraining 2
PRESENTED BY:
Daniels Training Services
815.821.1550
www.DanielsTraining.com
Info@DanielsTraining.com
A different kind of training.

3. HazMat Employee Training Requirements @DanielsTraining 3
A Question Before We Start…
• Have you
identified,
trained, and
tested all the
HazMat
Employees at
your facility?

4. HazMat Employee Training Requirements @DanielsTraining 4
SOME BACKGROUND
INFORMATION:
It is first necessary to clear up some potential sources
of confusion about the regulations, identify the Agency
that enforces them, and to clearly define some key
terms.

5. HazMat Employee Training Requirements @DanielsTraining 5
OSHA v. US DOT
Occupational Safety & US Department of
Health Administration Transportation
• Regulates safety in the
• Regulates the domestic
workplace.
transportation of
• Required training
includes: hazardous materials.
• HazMat Awareness. • Requires triennial
• OSHA Hazardous
training for all HazMat
Material. Employees.
• Hazardous Waste
Operations
(HAZWOPER).

6. HazMat Employee Training Requirements @DanielsTraining 6
Includes All Methods of Transportation

7. HazMat Employee Training Requirements @DanielsTraining 7
What is a Hazardous Material?
• Defined @ 49 CFR 171.8, a hazardous material
has been determined by US DOT to be capable
of posing an unreasonable risk to health, safety,
and property when transported in commerce.
• Hazardous Materials Table @ 49 CFR 172.101.
• Includes:
• Hazardous substances.
• Hazardous wastes.
• Marine pollutants.
• Elevated temperature materials.

8. HazMat Employee Training Requirements @DanielsTraining 8
More About Hazardous Materials
• Hazardous Substances – refer to 40 CFR 302.4.
• Hazardous Waste – any material subject to the
hazardous waste manifest requirements of the
US EPA. Doesn’t include CESQG’s.
• Marine Pollutants – refer to Appendix B of the
Hazardous Materials Table.
• Elevated Temperature Material – refer to 49
CFR 171.8 for full definition.

9. HazMat Employee Training Requirements @DanielsTraining 9
Hazardous Materials are Common
Materials

10. HazMat Employee Training Requirements @DanielsTraining 10
What is a HazMat Employer?
• Employees at least
one HazMat
Employee, and;
1. Transports a
hazardous material
in commerce, or;
2. Causes a
hazardous material
to be transported
in commerce,

11. HazMat Employee Training Requirements @DanielsTraining 11
Packaging Manufacturers are
HazMat Employers
3. Or;
designs, manufactur
es, fabricates, inspe
cts, marks, maintain
s, reconditions, repai
rs or tests a
hazardous material
package or package
component.

12. HazMat Employee Training Requirements @DanielsTraining 12
WHAT IS A HAZMAT
EMPLOYEE?
If you are a HazMat Employer you must identify and
train your HazMat Employees.

13. HazMat Employee Training Requirements @DanielsTraining 13
Defined at 49 CFR 171.8
Hazmat 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)
HUH?!?
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.

14. HazMat Employee Training Requirements @DanielsTraining 14
Defined at 49 CFR 171.8
Hazmat 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.

15. HazMat Employee Training Requirements @DanielsTraining 15
A HazMat Employee has
Pre-Transportation Responsibilities
• Determines the hazard
class of a hazardous
material.
• Selects a hazardous
materials packaging.
• For imports, provides
the shipper with
information about the
regulations.

16. HazMat Employee Training Requirements @DanielsTraining 16
A HazMat Employee
Fills & Closes HazMat
Packagings
• Fills or loads a
hazardous materials
packaging.
• Secures a closure on
a filled hazardous
materials package.

17. HazMat Employee Training Requirements @DanielsTraining 17
A HazMat Employee
Prepares HazMat Packagings
• Marks a package to
indicate that it contains
a hazardous material.
• Labels a package to
indicate that it contains
a hazardous material.
• Ensures a package is
in proper condition for
transportation.

18. HazMat Employee Training Requirements @DanielsTraining 18
A HazMat Employee
Assists the Vehicle Driver
• Blocks & braces and
segregates a HazMat
package in a transport
vehicle.
• Selects, provides, or affixes
placards for a transport
vehicle.
• Places warning signs,
blocks wheels, and sets
brakes on tank cars for
loading or unloading.

19. HazMat Employee Training Requirements @DanielsTraining 19
A HazMat Employee
Loads or Unloads HazMat
This includes the transfer of bulk
quantities.

20. HazMat Employee Training Requirements @DanielsTraining 20
A HazMat Employee
Provides Oversight and Supervision
• Certifies that a
hazardous material is
in proper condition for
transportation.
• Supervises HazMat
Employees.
• Is responsible for the
safety of transporting
hazardous materials.

21. HazMat Employee Training Requirements @DanielsTraining 21
A HazMat Employee
Handles 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.

22. HazMat Employee Training Requirements @DanielsTraining 22
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.

23. HazMat Employee Training Requirements @DanielsTraining 23
A HazMat Employee
Manufactures, etc. Packages
• Designs,
manufactures,
fabricates, inspects,
marks, maintains,
reconditions, repairs or
tests a package or
package component.

24. HazMat Employee Training Requirements @DanielsTraining 24
What Does a HazMat Employee Do?

25. HazMat Employee Training Requirements @DanielsTraining 25
HOW MUST I TRAIN MY
HAZMAT EMPLOYEES?
Once you’ve identified your HazMat Employees, you
must ensure they are trained and tested per the
requirements of 49 CFR 172, Subpart H.

26. HazMat Employee Training Requirements @DanielsTraining 26
The HazMat Employee Training
Requirements
• Required since 1992.
• Revised in 2003 & again
in 2010.
• Further revisions
proposed for some
HazMat Employee job
descriptions.

27. HazMat Employee Training Requirements @DanielsTraining 27
Training Requirements of
49 CFR 172, Subpart H
General Awareness/Familiarization
Function-Specific Responsibilities
Safety & Emergency Response
Security General Awareness
In-Depth Security

28. HazMat Employee Training Requirements @DanielsTraining 28
Training Requirements of
49 CFR 177.816
Professional Driving Skills

29. HazMat Employee Training Requirements @DanielsTraining 29
General Awareness/Familiarization
• Training that provides
familiarity with the
general requirements
of the HMR and
enables the HazMat
Employee to recognize
and identify hazardous
materials.
• All HazMat Employees
must receive general
awareness training.

30. HazMat Employee Training Requirements @DanielsTraining 30
• Training that provides
a detailed
understanding of HMR
requirements
applicable to the
function(s) performed.
• Each HazMat
Employee must be
trained on the specific
functions they are
required to perform.

31. HazMat Employee Training Requirements @DanielsTraining 31
• Training that covers the
hazards presented by
hazardous materials, safe
handling, emergency
response information, and
methods and procedures
for accident avoidance.
• All HazMat Employees
must receive this training.

32. HazMat Employee Training Requirements @DanielsTraining 32
• Training that provides a
general understanding of
the security risks
associated with HazMat
transportation, the
methods designed to
enhance transportation
security, and how to
recognize and respond
to possible security
threats.
• Since 2003 all HazMat
Employees must receive
this training.

33. HazMat Employee Training Requirements @DanielsTraining 33
• Training that provides a detailed understanding of
a company’s security plan including company
security objectives, specific security procedures,
employee responsibilities, actions to take in the
event of a security breach and the organizational
security structure.
• This training must be provided to HazMat
Employees who handle or perform regulated
functions related to the transportation of the
materials covered by the security plan or who
are responsible for implementing the security
plan.

34. HazMat Employee Training Requirements @DanielsTraining 34
Security Plan/In-Depth Security Training
Applicability
• Applicability
determined by type
and amount of
hazardous materials
shipped.
• Applicability
determination revised:
10.1.10.
• Refer to 49 CFR
172.800(b).

35. HazMat Employee Training Requirements @DanielsTraining 35
HazMat Employee Training
Requirements
• Full training every 3 years.
• Must receive training within 90 days of
employment or new job assignment.
Supervised in that time.
• 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.

36. HazMat Employee Training Requirements @DanielsTraining 36
HazMat Training Documentation
• Hazmat employee’s name.
• Most recent training
completion date.
• Description, copy, or location
of the training materials.
• Name and address of
person providing the
training.
• “Certification” that the
HazMat Employee has been
trained and tested.

37. HazMat Employee Training Requirements @DanielsTraining 37
HazMat Training Document Retention
• Current employees
until facility closure.
• Former employees at
least 90 days from last
day.

38. HazMat Employee Training Requirements @DanielsTraining 38
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.

39. HazMat Employee Training Requirements @DanielsTraining 39
This Any
concludes my Questions?
presentation:
HazMat
Employee
Training
Requirements
Contact me to Daniels Training Services
815.821.1550
learn more. www.DanielsTraining.com
Info@DanielsTraining.com