2022 Hazardous Waste/Materials Manifesting & Shipping (DOT)
Category : Programs
Employees who are assigned to any aspect of shipping and receiving of hazardous materials and hazardous wastes are required by California regulation to have annual training in addition to the DOT’s triennial training requirement. Due to unique and complicated California hazardous waste requirements, vigorous enforcement and high visibility of hazardous materials shipments, employers cannot afford to have untrained or poorly-trained employees.
Do You Need This Training?
DOT hazardous materials regulations are clear as to what employees need this training—a requirement not well understood [40 CFR § 172.702]:
“Applicability and responsibility for training and testing.
(a) A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart.
(b) …a hazmat employee who performs any function subject to the requirements of this subchapter may not perform that function unless instructed in the requirements
of this subchapter that apply to that function.
It is the duty of each hazmat employer to comply with the applicable requirements of this subchapter and to thoroughly instruct each hazmat employee in relation thereto.”
- Does This Apply to my Plant? A hazmat employee is any person who engages in any activity involving hazardous materials regulated by DOT’s 49 CFR regulations, including receiving or transporting hazardous material shipments and receipts from the receiving dock to first storage or use, and last storage or use to the transporting vehicle. This includes material handlers; forklift operators; any person who signs a bill of lading, manifest, or hazardous waste manifest; prepares any paperwork; assures regulatory compliance; or is involved in hazardous materials security.
- What’s a HazMat? Any substance or chemical listed at 49 CFR § 172.101 (there are nearly 1,000). Any quantity regulated by DOT triggers the training requirement.
- What Are the Training Requirements? The regulation requires that all hazmat employees receive training and testing on: familiarity with hazmat requirements and hazmat identification; functional training as to how to perform job tasks in compliance with hazmat requirements; and in hazmat safety. Formal training must be provided initially and repeated triennially, but the employer is liable for any mistakes, which suggests more frequent refresher training.
Training Topics Include:
- Introduction – Scope of DOT Hazardous Materials Regulations and applicability to hazmat employers and employees.
- Basic requirements for shipping and receiving hazardous materials, and shipping hazardous wastes.
- DOT Hazard Classes and Hazardous Materials Table.
- Shipping papers, including hazardous waste manifest and the e-manifest system.
- Other DOT requirements for hazardous materials shipping.
These and other important questions will be addressed during the webinar.
December 7, 2022