Compliance with DOT Hazmat Training Requirements
In 2013, there were over 16,770 incidents involving hazardous materials resulting in 175 injuries, 11 deaths and over 110 million dollars in property damage. Some of these incidents could have been avoided had employees received proper DOT training. Providing all employees with the necessary training not only helps an employer avoid accidents and injuries, but also reduces the risk of enforcement penalties costing thousands of dollars. Hazmat incidents don’t just temporarily impact your company, they can have lasting and even permanent effects on both its reputation and bottom-line.
DOT hazmat training is designed to ensure that hazmat shipments meet DOT hazmat requirements every time. According to the DOT website, all hazmat employees need training. Do you know which of your workers are DOT “hazmat employees”? It’s an employer’s responsibility to know and provide appropriate training to all of them.
Here are 4 questions to help you determine if your employees need DOT hazmat training.
1. Is your employer shipping unrecognized, undeclared hazardous materials?
The long list of substances that are considered hazmat can be daunting and intimidating. Some of the materials on the list are commonly overlooked and the employees responsible for shipping them, left untrained. Examples include:
Genetically-modified micro-organisms and organisms
Environmental samples for analysis
Batteries (lithium, button, or gel cell)
Scientific instruments with compressed gas cartridges/canisters/cylinders
Equipment with compressed air chambers or pistons
Electronic devices/ computer equipment with lithium batteries installed
Contaminated medical equipment and devices
Devices with fuel cells
Before opting out of DOT hazmat training, conduct a thorough review of each employee’s responsibilities and tasks related to hazmat at your facility. If an employee is classifying, packaging, labeling, marking, or preparing shipping papers for hazardous materials to be shipped, then that employee needs DOT hazmat training. In the following sections, we will give you examples of tasks that may trigger the need for DOT hazmat training for your personnel.
2. Is your employer identifying and classifying hazardous materials or profiling hazardous wastes correctly?
There are employees responsible for determining what is, and what isn’t, regulated as hazardous material. Failure to classify a material correctly could have serious consequences, including creating dangerous situations for individuals and the general public. This task should only be given to individuals that are well trained and have a high degree of competency and experience.
3. Are all the hazmat employees competent with regard to selecting and preparing packagings for shipment?
There are many complex regulatory issues associated with packaging, including understanding general survivability requirements, manufacturers’ specifications, UN or DOT-specification testing standards, quantity limitations, specific packaging instructions/authorizations, the use of exceptions and special permits, and issues related to reuse and reconditioning. To perform packaging-related tasks correctly requires a high degree of understanding of, and proficiency with, the regulations.
4. Have all your hazmat employees been trained every 3 years, or when their responsibilities change?
All hazmat employees must go through DOT hazmat training at least once every three years . Training must be documented appropriately and be readily available for inspection. Additionally, if employees’ hazmat-related functions change, they must receive additional detailed training addressing those regulatory topics not previously addressed.
Have employees that need to be trained? Get details on our upcoming webinar.