HM Training Requirements

1
College and University Hazardous Waste
Conference
2
Federal Hazmat Law

• Protect against the risks to life, property, and
  the environment which are inherent in the
  transportation of hazardous materials in
  intrastate, interstate, and foreign commerce

U.S. Senate Photo
49 U.S.C. Section 5101 et seq.
3
Hazardous Materials Regulations
The Department of Transportations Hazardous
Materials Regulations (HMR 49 CFR Parts 171-180)
govern the packaging and safe transportation of
hazardous materials by air, highway, rail, and
water (except bulk transportation onboard vessels)
4
Responsibilities

• DOTs Pipeline and Hazardous Materials Safety
  Administration (PHMSA) formulates, issues and
  revises, and enforces the HMR and issues special
  permits and approvals under the Federal hazmat
  law
• PHMSA enforces regulations emphasizing
• Packaging Manufacturers, Retesters and
  Reconditioners
• Multimodal shippers of hazmat

5
Responsibilities (cont)

• Modal administrations (FAA, FMCSA, and FRA)
  enforce the HMR respective to their mode
• U.S. Coast Guard (Department of Homeland
  Security) enforces the HMR respective to maritime
  operations

6
Common Problems Found During Inspections

• Failure to maintain training records
• Failure to provide training to hazmat employees
• Packages not properly marked and labeled
• Incorrect shipping papers
• Failure to register with PHMSA
• Lack of Security Plan

7
Training Requirements
8
Training Requirements

• HMR training requirements are found in 49 CFR,
  Part 172, Subpart H

DOT/PHMSA Photo
9
Additional Modal Training Requirements

• Air - 175.20
• Highway - 177.800 and 177.816
• Vessel - 176.13

10
Reference Material
11
Applicability Responsibility

• A hazmat employer shall ensure that each of
  its hazmat employees is trained

The responsibility for training (and the civil
penalties for not training) rests with the
employer
172.702(a)
12
Training Requirements

• Hazmat employee training must include
• General awareness / familiarization training
• Function-specific training
• Safety training
• Security awareness training
• In-depth security training (when applicable)

172.704(a)
13
General Awareness and Familiarization

• Designed to
• Provide familiarity with the requirements of the
  HMR
• Enable hazmat employees to recognize and identify
  hazardous materials using the hazard
  communication standards found in the HMR

172.704(a)(1)
14
Function Specific

• Each hazmat employee shall be provided
  function-specific training concerning
  requirements of this subchapter, or exemptions
  issued under subchapter A of this chapter, which
  are specifically applicable to the functions the
  employee performs

172.704(a)(2)(i)
15
Safety Training

• Safety training must cover
• Emergency response information required by HMR
• Measures to protect the employee from the hazards
  associated with hazmat to which they may be
  exposed
• Methods and procedures for avoiding accidents,
  such as the proper procedures for handling
  packages containing hazardous materials

172.704(a)(3)
16
Security Awareness

• Required for all hazmat employees
• Provide an awareness of security risks associated
  with hazmat transportation
• How to recognize and respond to possible security
  threats

172.704(a)(4)
17
Security Awareness (cont)

• Hazardous Materials Transportation Security
  Awareness Training Module
• Satisfies security awareness training requirement
  in HMR
• Provides an overview of hazmat transportation
  security issues and helps identify and address
  security risks

18
In-Depth Security Training

• Required for each hazmat employee of a person
  required to have a security plan in accordance
  with Subpart I of Part 172
• Training must include
• Company security objectives
• Specific security procedures
• Actions to take in the event of a security breach
• Employee responsibilities,
• Company organizational security structure

172.704(a)(5)
19
Reference Material
20
Training Source

• Training may be provided by the employer or
  other public or private sources

DOT/PHMSA Photo
172.702(c)
21
Training Source

• DOT does not approve, endorse, or certify
  anyones training program or product
• The hazmat employer certifies that a hazmat
  employee has been trained

DOT Certified
The FAA does approve the internal hazmat training
program of air carriers
22
Testing

• A hazmat employer shall ensure that each of its
  hazmat employees is tested by appropriate means
  on the training subjects covered in 172.704

DOT/PHMSA Photo
The HMR does not set testing methods or pass
standards. The responsibility is the hazmat
employers
23
OSHA or EPA Training

• Training completed to meet OSHA or EPA
  requirements that addresses training specified in
  172.704(a) may be used to satisfy the HMR
  training requirements.

172.704(b)
24
Training Frequency

• Initial training must be completed within 90 days
  of hazmat job start or change in job function
• Until trained, a hazmat employee must be directly
  supervised by a trained and knowledgeable
  employee
• Recurrent (refresher) training is required at
  least every three years.

172.704(c)(1) and (2)
25
Relevant Training

• Hazmat training received from a previous employer
  or other source can be used to meet the DOT
  requirements provided that a current record of
  training is obtained from the previous employer

172.704(c)(3)
26
Recordkeeping

• The training record must include
• Hazmat employees 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

LOC Photo
172.704(d)
27
Sample Training Record
28
Training Resources

• PHMSA offers numerous
• training aids
• Hazardous Materials
• Transportation Training
• Modules CD ROM
• Videos
• Transportation Safety Institute
• http//www.tsi.dot.gov
• A list of Hazardous Materials Training and
  Transportation Consultative Services is available
  at http//hazmat.dot.gov/common/thirdpty.htm

29
Shipping Papers and Emergency Response Information
30
Objectives

• Define Requirements of the Hazardous Materials
  Regulations (HMR) Pertaining to Shipping Papers
• Describe Required Entries on Shipping Papers
• Identify Emergency Response Information that Must
  Accompany Shipping Papers

31
Subpart C Shipping Papers

• A shipping order, bill of lading, manifest, or
  other shipping document serving a similar purpose
  and containing the information required by HMR
  Part 172, Subpart C

171.8 172.200
32
Shipping Paper

• Each person who offers a HM for transportation
  shall describe the hazardous material on the
  shipping papers as required in 49 CFR Part 172
  Subpart C

The UHWM can be used as a shipping paper
49 CFR 172.205
33
Shipping Papers Continued

• If it is listed in 49 CFR 172.101Hazardous
  Materials Table
• then a complete shipping description must be on
  the shipping document
• For Hazardous Waste the word Waste shall
  precede the basic description of listed HM on
  shipping document.

49 CFR 172.101 ( c) ( 9)
34
Uniform Hazardous Waste Manifest

• Required for EPA wastes
• DOT shipping description
• Proper Shipping Name
• Hazard Class
• ID Number
• Packing Group
• Package type and count
• Note container codes are not found in DOT
  regulations see 40 CFR Part 262, Appendix

40 CFR 262.20
49 CFR 172.205
35
UHWM Continued

• Handwritten signatures
• Multiple copies
• Copy kept for 3 years by both Carrier and
• Shipper / Generator

40 CFR 262.40
36
Hazardous Waste Shipments
9a. HM
9b. U.S. DOT Description (including Proper
Shipping Name, Hazard Class, ID Number, and
Packing Group (if any)
1A1
X
Waste, Acetone, 3, UN1090, PGII
5 gal
1
172.205
37
Required Information
Hazardous Materials Descriptions and Proper
Shipping Names (2)
(8) Packaging (173.)
(9 Quantity Limitations
Hazard Class or Division (3)
Special Provisions (172.102) (7)
Label Codes (6)
Identification Numbers (4)
Cargo air- craft only (9B)
Symbols (1)
PG (5)
Passenger aircraft/rail (9A)
Excep- tions (8A)
Non-bulk (8B)
Bulk (8C)
6.1
I
6.1, 3
1, B9, B14, B30, B42, B72, B77, T22, TP2, TP7,
TP13, TP38, TP44
Forbidden
Forbidden
None
226
244
Acrolein, stabilized
UN1092
6.1
II
6.1
IB8, IP2, IP4
25kg
100kg
None
204
242
Copper cyanide
UN1587
3
I II III
3 3 3
T11, TP1, TP27, 1B2, T7, TP1, TP8, TP28, B1, B52,
IB3, T4, TP1, TP29
1L 5L 60L
30L 60L 220L
150 150 150
201 202 203
243 242 242
Flammable liquid, n.o.s.
UN1993
G
A7, IB3, IP3, N34, T4, TP1
5L
60L
154
203
241
Phosphoric acid solution
III
8
8
UN1805
172.101 Hazardous Materials Table Excerpts
38
Hazardous Materials Descriptions

• Proper shipping name (PSN)
• Hazard class or division
• (Subsidiary risks)
• Identification number
• (May be placed before PSN)
• Packing Group
• Technical names (required for n.o.s. entries)
• Total quantity
• Mass, volume, or activity for Class 7
• Number and type of packages

172.202
39
Preparation of Shipping Papers

• Display of Hazardous Materials Description on
  Shipping Papers
• Listed first or
• Contrasting color
• Identified with X in HM Column
• Legible
• English
• Authorized abbreviations
• Additional information
• Continuation pages
• Emergency response telephone number

172.201
40
Additional Descriptions

• Special Permits/Exceptions
• DOT-SP
• DOT-E
• Limited Quantity (Ltd Qty)
• Hazardous Substance
• RQ
• Radioactive Material
• Empty Packages
• Transportation by modes
• Marine Pollutants

172.203
41
Describing Hazardous Materials
42
Shipping Papers

• Phosphoric acid solution, 8, UN1805, PGIII

4 Drums
4 gal
312 lbs
172.202
43
Shipping Papers
4 Drums
X
UN1805, Phosphoric acid solution, 8, PGIII
4 gal
312 lbs
UN1993, Flammable Liquids, n.o.s. (contains
methanol), 3, PGIII
100 gal
2 Drums
X
896 lbs
This shipment is within limitations for cargo
aircraft only
172.201 172.202 172.203
44
Shipping Papers
RQ, Copper cyanide, 6.1, UN1586, PGII, Marine
Pollutant
X
10 lbs
1 Box
35 lbs
172.203
45
Shipping Papers
UN1587, Copper cyanide, 6.1, PGII, Marine
Pollutant
RQ
10 lbs
1 Box
35 lbs
172.203
46
Shipping Papers
Acrolein, stabilized, 6.1(3), UN1092, PGI, Toxic
Inhalation Hazard, Zone A
10 Drums
1 gal
560 lbs
172.202 172.203
47
Shipping Papers
4 Drums
X
UN1805, Phosphoric acid solution, 8, PGIII
4 gal
312 lbs
UN1993, Flammable liquids, n.o.s. (contains
methanol), 3, PGIII
896 lbs
2 Drums
X
100 gal
1 Box
Carriage bolts
1000
100 lbs
This shipment is within limitations for cargo
aircraft only
172.201
48
Shipping Papers
1 Box
Carriage bolts
1000
100 lbs
312 lbs
4 Drums
X
UN1805, Phosphoric acid solution, 8, PGIII
4 gal
UN1993, Flammable liquids, n.o.s. (contains
methanol), 3, PGIII
896 lbs
2 Drums
X
100 gal
This shipment is within limitations for cargo
aircraft only
172.201
49
Shipping by Air
UN 1993, Flammable Liquids, n.o.s.,
(contains methanol), 3, PGIII//1Steel Drum x 200
L//309
50
Shippers Certification
Each person who offers a hazardous material for
transportation shall certify that the material is
offered for transportation in accordance with the
HMR
Emergency Contact 1-800-555-1234
This is to certify that the above-named materials
are properly classified, described, packaged,
marked and labeled, and are in proper condition
for transportation according to the applicable
regulations of the Department of Transportation.
Signed Date
172.204
51
Emergency Response Telephone Number
UN1805, Phosphoric acid solution, 8, PGIII
1-800-555-1234
4 Drums
X
4 gal
312 lbs
UN1993, Flammable liquids, n.o.s. (contains
methanol), 3, PGIII
2 Drums
X
100 gal
896 lbs
This shipment is within limitations for cargo
aircraft only
172.201(d) 172.604(a)(3)
52
Emergency Response Telephone Number
1-800-555-2222
1 Box
Carriage bolts
1000
100 lbs
312 lbs
4 Drums
X
UN1805, Phosphoric acid solution, 8, PGIII
4 gal
UN1993, Flammable liquids, n.o.s. (contains
methanol), 3, PGIII
896 lbs
2 Drums
X
100 gal
This shipment is within limitations for cargo
aircraft only
172.201 172.604(a)(3)
53
Shipping Paper Retention

• Copy or electronic image
• Include date of acceptance by initial carrier
• Retained by shipper for two years
• Retained by carrier for one year
• Hazardous waste retained by shipper and carrier
  for three years
• Accessible at or through principal place of
  business
• Must be made available upon authorized official
  request

172.201(e)
54
Emergency Response Telephone Number

• Person monitors at all times during
  transportation
• Is knowledgeable of the hazardous materials
  listed
• Has comprehensive emergency response and
  incident mitigation information for that
  material or
• Has immediate access to a person who possesses
  such knowledge
• Accepts Responsibility

172.202(d) 172.604
55
Providing Emergency Response Information

• During transportation and at facilities where
• Loaded for transportation
• Stored incidental to transportation
• Handled during any phase of transport
• Applies to persons who
• Offer for transportation
• Accept for transportation
• Transfer during transportation
• Handle during transportation

172.600(a)(b)
56
Availability of Emergency Response Information

• All times Hazardous material is present
• Immediately available during accident or incident
  to emergency personnel
• Includes emergency response telephone number
• During investigations to
• Federal, State or Local government
  representatives

172.600(c)(1)(2)
57
Emergency Response Information

• Basic description and technical name
• Immediate hazards to health
• Risks of fire or explosion
• Immediate precautions to be taken in the event of
  an accident or incident
• Immediate method for handling fires
• Initial methods for handling spills or leaks in
  the absence of fire
• Preliminary first aid measures

172.602
58
Presenting Emergency Response Information

• Printed legibly in English
• Availability away from hazardous materials
  package
• On shipping paper or document that includes
• Basic description
• Technical names

172.602(b)
59
Emergency Response Guidebook (ERG)

• Aids emergency responders
• Identifies specific or generic hazards of
  material(s)
• Provides for protective actions

60
Where to Find More Information . . .
http//hazmat.dot.gov
61
How Can You Reach Us?

• Hazardous Materials INFO-LINE
• 1-800-HMR49-22
• (1-800-467-4922)
• Hours of Operation 9 am 5 pm ET

• Obtain answers to HMR questions
• Request copies of Federal Register, exemptions or
  training materials
• Report HMR violations
• Fax on Demand

DOT/PHMSA Photo
E-mail infocntr_at_dot.gov