A new feature of our blog is our “Ask the Expert” column. Each column will feature a frequently asked safety question, and one of our safety experts will provide an answer.
This week's question will be answered by Chris Fulmer a certified Environmental, Safety and Health Trainer (CET) through NESHTA and The Board of Safety Professionals, and Certified Hazardous Materials Practitioner (CHMP) with IHMM. Mr. Fulmer has over 25 years of experience in hazardous materials emergency response, hazardous waste remediation, EHS consulting and Project Management.
As an employer, which of my employees need Department of Transportation Training (DOT) in Hazardous Materials Shipping, Receiving and Transporting?
Over the course of many years of training companies and employees on Department of Transportation Training (DOT) Hazardous Materials Shipping, Receiving and Transporting, one consistent question has always been asked; “who actually needs DOT Training?”
This question arises because it can be confusing, and the regulations can seem vague depending on what the employee’s job task may actually be. We all know that the person that signs the manifest should be trained and certified, and usually most know the forklift driver loading the truck should be as well. But who else?
The regulation basically says that any hazardous materials employee that directly affects the safe shipping, receiving, or transporting of hazardous materials and waste requires training. So that can include a vast array of employees.
To help clarify, below are some examples of who should be DOT certified:
- The signer of a bill of lading or manifest shipping AND receiving the hazardous materials
- Any employee that may fill out a manifest or bill of lading, even if they do not sign it
- The forklift operator that loads or unloads a vehicle with hazardous materials or waste
- Any employee that determines what hazardous material goes into or on a specific transport vehicle
- Any operator of a transport vehicle that will go onto public transport
- Any employee that puts DOT labels onto containers to be shipped
- Any employee that packages hazardous materials for shipping. Be it drums, boxes, buckets, etc.
- Any employee that may purchase containers for shipping hazardous materials, if they are the one deciding what container is required for safe shipping.
- Any employee that inspects containers for use in hazardous materials shipping.
It basically comes down to any employee or individual that may directly interact with a hazardous material that is being offered for shipment on public transport (highway, air, rail and vessel). And DOT states that any HazMat employee must be trained and certified in:
- General awareness and familiarization of the regulations
- Function specific training – proper shipping, manifests, labels and placards, proper containers, etc.
- Safety training - loading and unloading risks, emergency response, etc.
- Security awareness
- Any job specific training required
Once an employee is certified, then they must be re-certified every 3 years (at minimum) to ensure they are updated on any regulatory changes, current on specific company policies and regulations and are current on relative information.
The best way to determine which of your employees may be considered a hazmat employee per DOT and require certification, is to ask these questions:
- Am I a shipper or receiver of hazardous materials by public transport?
- Do I directly interact with hazardous materials being shipped, received or transported?
- Do my actions with this hazardous material affect the safety of the public in transport?
If you answer yes to any of these questions, then you or that employee may need to be DOT Hazardous Materials Shipping, Receiving or Transporting certified.
If you still have questions or concerns as to if you or any of your employees should be certified, or what qualifies as a hazardous material being shipped or received, you can contact your Arbill Representative for further information.
Looking for additional training for your employees? Talk to one of our safety advisors today and schedule a site assessment or training program.
Arbill is a safety solutions company. We are all about protecting your workers in the workplace. Our mission is to keep workers safe and return them home safely at the end of the day. Visit arbill.com for more information about being safe and subscribe to Safer Every Day, the definitive digital magazine for workplace safety.
Have a safe day!