managing complex training ecosystems in a post lms era
TRANSCRIPT
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SIMPLYFING HAZMAT TRAINING Managing Complex Hazmat Training in a Post-LMS Era
By Melissa Powers Regulatory Compliance Analyst AQT Solutions [email protected] www.aqtsolutions.com
August 28, 2015
TRAINING RECORDS IN THE HAZMAT WORLD
Hazmat employers in the U.S. must comply with complex recordkeeping requirements based on 49 CFR
172.704 (d) which dictates that employers must keep a hazmat employee’s current training records and
those of the previous 3 years as long as the individual remains an employee. These records include the
most recent completion dates, description of training materials, names and addresses of training providers,
and finally a certification that the employee has been trained and tested. This is usually in the form of a
standard “certificate of completion” that can be provided to the trainee but then is maintained by the
employer. All of these records must be maintained during the period of employment and for 90 days after
the employee is no longer employed. The employer must make this information available to the DOT upon
request. If your company ships to, or from, the U.S. and follows the IATA DGR’s the same DOT
recordkeeping rules apply. OSHA hazard communication and blood borne pathogen standards also require
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training and subsequent recordkeeping that employers maintain for inspector review. OSHA can expand
into areas beyond hazmat that require extensive recordkeeping such as power industrial trucks in 29 CFR
part 1910.178 where initial training is required along with subsequent training to determine the trainee
possesses essential knowledge. Training must be instructional as well as practical and involves a final
evaluation of the trainee. The recordkeeping requirements for power industrial training dictates the
operator to record the date of training, date of evaluation and refresher training. The common theme
running throughout all of these regulatory entities, whether it be DOT, TSA, or OSHA, is that training records
must be retained and reproduced for inspectors.
The reality is that a lot of companies rely on paper methods or spreadsheets to manage their training.
Having a training management system offers the freedom to break away from these sometimes risky
practices by electronically managing training courses and records. When paper records are the only method
of tracking and retaining training information, managers are often unsure of where a trainee’s status
actually stands; ATMS (Advanced Training Management System) allows for a centralized data repository
with a summary of each trainee’s real time status, history and future training requirements. Companies
that manage an extensive catalog of training with varying regulatory bodies across many modes of
transport and geographic locations can especially benefit from the ability to centrally locate and manage
all of their training courses. Our system is designed to build parameters surrounding each course based on
the governing regulators’ requirements.
CONSOLIDATING RECORDKEEPING IN A SINGLE SYSTEM
ATMS combines regulatory compliance training requirements into a single, integrated recordkeeping
system which substantially reduces the possibility of missed or overlooked training requirements. Our
system allows training records to be maintained within one centralized location across multiple regulatory
agencies; completion dates and scores can be viewed for all training courses. ATMS can also be used to
store and manage employee certifications and personal HR data and identifying information (STAs, SIDA
badges, employee IDs, passports, etc…). It is essentially a one-stop shop for all training and recordkeeping
data.
TRAINING HELPS PREVENT HAZMAT INCIDENTS
The majority of transportation incidents involving hazardous materials are the result of human error;
training is the best approach to incident prevention. The burden of maintaining training records between
a small and large corporation is the same. Whether a company is large or small, they are faced with the
same challenge of maintaining safety and compliance within a complex regulatory environment. Smaller
organizations tend to have less resources dedicated to tracking their employee training records. Those
duties may be split among multiple personnel responsible for different groups of trainees, each using their
own recordkeeping methods. Large corporations manage higher volumes of employee training and may
have more resources dedicated to recordkeeping, but do not have a cohesive way to effectively manage
their process. They also may be burdened with providing vendor/partner training across multiple
geographic locations. Regardless of the size of an organization, there are common challenges that
companies face when they are relying on manual processes.
A training management system helps companies organize and issue their training materials, deliver the
training, record, and store the required results and information. ATMS basically allows organizations to
manage training and recordkeeping more efficiently, and be better prepared for regulatory audits.
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GLOBAL MULTI-MODAL TRAINING COMPLIANCE
It’s not necessarily easier. Hazmat training requirements in subpart H of part 172 apply to each mode of
transportation. However, depending on the mode of transport, the carriers must follow their respective
part within 49 CFR (air/highway/vessel/rail). There may be slight variations among the requirements on
where training records are to be maintained and additional regulations that must be followed within each
part. An air carrier for example would have to comply with 14 CFR parts 121 and 135 in addition to part
172 subpart H. Highway carriers that employ drivers need to ensure parts 390-397 are being followed. It
can actually get pretty complicated when using multiple modes to transport hazardous materials. The U.S.
government does provide an electronic code of federal regulations free of charge which makes it extremely
easy to navigate around the regulations but that doesn’t necessarily make the recordkeeping aspect easier.
Companies still need to comply with subpart H but also ensure they are not missing any nuances within
their specific mode of transport.
European carriers deal with separate regulations for mode of transport including RID, ADR, IMDG and IATA
DGR’s and depending on mode of transport could be juggling all of these regulations or just some of them.
The effectiveness of ATMS is it allows companies to manage the training requirements of each regulatory
agency. Training is designed in the TMS based on regulatory oversights such as frequency and re-currency
of each training curriculum. Because ATMS is built to manage regulatory compliance, it is designed to look
at a multitude of factors that could affect the currency of training such as test scores and grace periods. A
company that has to follow multiple regulations benefits from a system like ATMS because it can manage
an unlimited number of training courses that each come with varying oversight and requirements.
HOW A TMS IMPROVES HAZMAT TRANSPORTATION
ATMS offers efficiency and organization to every company conducting qualification-based training with
regulatory based materials; it maximizes productive by eliminating human errors and valuable time from
manual recordkeeping, filing, and updating spreadsheets. The system manages the entire training process
from course set-up to scheduling resources (trainees, instructors, and devices such as classroom and CBT
for eLearning), recordkeeping, and maintaining recurrent training. Automatic re-queuing and notifications
allow peace of mind that trainees will not go past their training due dates.
One of the many advantages between ATMS and a typical LMS is that ATMS provides unlimited training
courses (from classroom to eLearning) without charging additional fees; an LMS will charge a fee for every
course taken. Even for a small size company, the cost could be exorbitant if each employee has to take
multiple courses to complete their annual training requirements. Another advantage ATMS has over an
LMS is that it is an integrated training system with a built in LMS to manage all eLearning content;
companies will no longer have to pay for an LMS service!
Whether a company decides to use ATMS installed on-site or in a hosted environment, the feasibility of the
system provides plenty of options to meet all needs, as well as experiencing award winning customer
service from AQT Solutions.
COMMON ERRORS A TMS CAN HELP AVOID
Relying on manual recordkeeping process that allow for a lot of human error and simply not maintaining
training and trainee information in one location. The reality is most companies have many different
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departments managing their training processes. So, you are not seeing simply one department that
manages training for an entire company. These responsibilities are spread out over an organization and
multiple managers which can create miscommunication and disorganization. ATMS allows all of these
departments to essentially come together. A trainee exists once in the system but everyone can see where
that employee stands in regards to all of their training records and information.
Organizations also run into pitfalls when trying to use only an LMS to manage their training. They may
receive notifications of completion but the actual management of the trainee and all aspects surrounding
their currency are not handled. Companies often purchase courses through an LMS provider but then have
little control over the management of the courses or the billing for those courses. They are even charged
by the LMS vendor for delivering courses that were developed and owned by the company. ATMS is a TMS
with a built-in LMS, managing all training requirements for those in the regulated environment. ATMS goes
beyond just completing an eLearning course and getting a notification by managing multiple training
schedules, collecting grades on any type of training, handling vendor training they may be responsible for,
manage training expiration dates for qualifications, handle recurrent training, and managing currency
CHOOSING THE BEST HAZMAT TRAINING WITH A SYSTEM IN MIND
Purchase training courses from reputable companies that are members of their respective trade
associations/groups. Understand employee job duties and ask for employee feedback on training.
Employees are key indicators regarding effective training; after all they want to be confident at their job
duties. It may be wise to review a course for effectiveness or ask others in peer groups for recommended
courses. Courses are not given a seal of approval by government agencies so it is important that
organizations understand the regulations and know what is required for proper training of their employees.
ATMS provides a modern, integrated system that maintains accuracy and currency of training records that
gives companies the confidence and assurance to be audit-ready and compliant.
AQT SOLUTIONS www.aqtsolutions.com