regulatory training: who needs it and how much?

Training: Who needs it?

And how much?DOT Hazardous Materials and IATA

Meet Your Moderator:

Sasha Laferte

1. All lines are muted, use the chat panel for tech issues.

2. Ask questions using the questions panel

3. Unanswered questions will be answered via email after the webinar

4. Webinar recording and slides will be emailed to you tomorrow morning.

A Few Logistical Items

Meet Your Presenter

Doug Graham, CHMM

Sr. EH&S Consultant & External Training Manager

[email protected]

22 Years training hazardous materials shippers

mailto:[email protected]

OBJECTIVE

Learn who needs DOT Hazardous Materials and IATA

training and how much.

Transporting Hazardous Materials: DOT & IATA

Who needs it?

How much do they need?

Potential consequences of falling short

DOT TrainingU.S. Department of Transportation Hazardous Materials

Regulations (49 CFR 100-185) Training

Basic OverviewRequired every 3 years

5 training elements

Applicable to “hazmat employees”

Non-prescriptive

Training Requirements49 CFR 172.704

Required Elements:172.704(a)(1): General Awareness172.704(a)(2): Function-Specific172.704(a)(3): Safety172.704(a)(4): Security Awareness172.704(a)(5): In-Depth Security

Applicable to “hazmat employees” as defined in 49 CFR 171.8 (those who affect hazmat transportation safety)




Consists of an overview of those regulatory topics which do not directly affect the employee’s hazmat-

related tasks. The training can be shorter and in less detail, but cannot be skipped.

172.704(a)(1): General Awareness




172.704(a)(2): Function-Specific

Training in regulatory topics that directly affect the employee’s job functions- must be in sufficient detail and length to cover the topic thoroughly.




172.704(a)(3): Safety

DOT does not mandate any additional training under this paragraph, but does require that hazmat

employees be trained in related safety requirements, mentioning specifically OSHA’s Hazard

Communication and HAZWOPER standards.



Required Elements:172.704(a)(1): General Awareness172.704(a)(2): Function-Specific172.704(a)(3): Safety172.704(a)(4): Security Awareness172.704(a)(5): In-Depth Security172.704(a)(4): Security Awareness

All hazmat employees must receive an overview of the role that hazardous materials have played, and

may continue to play, in terrorist activities and to safeguard against illicit use of such materials and

address potential security risks



Required Elements:172.704(a)(1): General Awareness172.704(a)(2): Function-Specific172.704(a)(3): Safety172.704(a)(4): Security Awareness172.704(a)(5): In-Depth Security172.704(a)(5): In-Depth Security

In accordance with 49 CFR 172.800-822, certain shippers and carriers must develop and implement

site-specific written security plans. Those employees who have roles and responsibilities under the plan must receive training in the specifics of the plan.


• Training is required every 36 months for all hazmat employees.

• Records must be maintained for the duration of employed, plus an additional 90 days.

• New employees must be trained within 90 days.

• Records must include certification that the employee was trained and tested.

Who are the Hazmat Employees?

• Only hazardous waste manifest signers and shipping departments really need DOT Hazardous Materials training

Common Misconception

• There are many types of employees involved who perform pre-transport functions related to hazmat shipments. A common problem amongst employers is having unidentified, untrained hazmat employees acting independently.

Reality (all “hazmat employees”)

Hazmat Employees(other than hazardous waste manifest signers)

Shipping/Receiving

• Hazardous products, articles and chemicals (sending/receiving and potentially returning)

IT • Lithium batteries

Lab Personnel• Potentially infectious biological materials, dry ice,

formaldehyde

Researchers • Genetically modified microorganisms, new compounds

Healthcare • Patient specimens

EVS/Housekeeping

• Regulated medical waste

Other• Purchase or reuse UN-spec packagings• Self-transport

How Much Do They Need?

• Length and curriculum of training not specified.

• How many hours devoted to DOT training is up to the employer and should depend on the employees’ specific job function.

How Much Do They Need?Depending upon job function, some employees may require supplemental “function-specific” training beyond a basic course, including those involved in:

• Shipping radioactives• Shipping by air (IATA)• Using special permits• Having an active role in a security

plan

How Much Do They Need?Although not specifically required following a comprehensive basic training, some employees may find that specific supplemental training in a particular topic to be helpful, for example:

• Shipping lithium batteries• Shipping infectious

substances

Potential Consequences of Falling Short

Incidents affecting public safety and/or the

environment

Rejected shipments

Civil penalties up to $75,000 per violation

IATA Training International Air Transport Association Dangerous

Goods Regulations

Basic OverviewPurpose was to create uniformity among airlines and comply with international air regulations (ICAO)

Required every 3 years (not 2)

DOT is a pre-requisite

DOT allows the use of IATA regs and most are enforceable by DOT (through the FAA)

Who Needs It?Common Misconception

• Only those involved in shipping hazardous materials internationally by air require IATA training

Reality

• All employees involved in preparing and shipping hazardous materials internationally and domestically by FedEx Express, commercial passenger airlines or UPS (international only) require IATA and DOT training

IT • Packaging and shipping lithium

batteries

Lab Personnel• Preparing shipments containing dry

ice

Researchers• Offering shipments of articles and

devices, and new compounds

Employees commonly overlooked:

Who Needs It?

How Much Do They Need?• IATA training is considered a function-specific element

of DOT training and is therefore also required every 3 years

• Like the DOT regulations, hazmat employees need training in the level of detail commensurate with the tasks they perform

See USDOT letter of interpretation #09-0240, dated July 2, 2010.




172.704(a)(2): Function-Specific

IATA training falls under the function-specific DOT training paragraph.

IATA Training Sec. 1.5 is not enforceable unless the provision is also required under 49 CFR 172.700-704

How Much Do They Need?Depending on job function, some employees may require supplemental training, including:

• Shipping radioactives• Shipping lithium

batteries• Shipping infectious

substances

Potential Consequences of Falling Short

• Incidents affecting public safety and/or the environment• Rejected shipments (very common)• Civil penalties up to $75,000 per violation (issued by the

Federal Aviation Administration (FAA))• Follow-up FAA inspections

Additionally, it is very common for FAA to perform routine and random inspections of shippers who complete Dangerous Goods Declaration forms.

ConclusionIt’s up to the employer to make

sure all hazmat employees are trained appropriately.

Other Training RequirementsOther training requirements typical for EH&S professionals include:

• Emergency Response (HAZWOPER)

• Hazardous Waste Management (RCRA)

15 Separate OSHA Standards, including• Hazardous Chemicals in Laboratories• Control of Hazardous Energy (Lockout-Tagout)• Confined Spaces• Bloodborne Pathogens• Electrical Safety• Hazard Communication• Access to Exposure and Medical Records• Cranes• Powered Industrial Trucks• Portable Fire Extinguishers• Employee Emergency Plans• First Aid

QUESTIONS?

Thank You For Attending!

• You will receive an email tomorrow with a copy of this presentation

• Please complete our short survey

• Expect a transcribed copy of the Q&A as well as a special offer.

regulatory training: who needs it and how much?

Business

security awareness172

general awareness172

employees hazmatrelated

iata training

dot hazardous materials

required elements

dot iata dot training

additional training