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New DOT Requirements!!
 New DOT requirements that became effective on June 1, 2005, trigger DOT training for a vast number of employees at industrial facilities that ship out and/or receive hazardous materials.
For the first time employees not previously defined as hazmat employees in 49 CFR, are now subject to DOT training requirements due to either their loading, unloading, or pre-transport job duties involving hazardous materials and/or hazardous waste. In addressing the applicability of 49 CFR regulation to hazmat shippers/generators, DOT introduced legal definitions for: Pre-Transportation Functions (15 different activities); Loading Incidental to Movement of hazardous materials; as well as Unloading Incidental to Movement (reference link to DOT 49 CFR regulations). In short, if hazardous materials are being loaded or unloaded by industrial facility (shipper/generator) personnel, and carrier personnel are present (prior to the carriers departure), industry employees performing the loading/unloading require DOT training. Also any shipper/generator employee that directly affects hazardous materials transportation safety requires DOT training, as defined by 15 Pre-Transport Functions.
Both DOT and RCRA training provided by SEEM/ERTC covers the new hazardous waste manifest form and manifesting requirements – effective in 2006. The introductory and recurrent DOT training courses provided at the SEEM/ERTC in Findlay, Ohio satisfies DOT training and testing certification requirements (reference link to 2006 catalog). DOT training as well as RCRA training can be brought to industrial facility locations with large numbers of employees requiring training. Professional, seasoned SEEM/ERTC instructors will customize training programs to cover only those requirements applicable to a particular facility. Training programs can be combined with others to satisfy multiple regulatory requirements with one training event.
Introduction
Did you know- "Any industry personnel that sign a hazardous waste manifest are required to have DOT Training in addition to RCRA Training, and that DOT Training must include Hazardous Materials Security Awareness, relative to the risk of hazardous materials being utilized as weapons of mass destruction."
All hazardous wastes are DOT hazardous materials when shipped off-site from industrial locations. The hazardous waste manifest, an EPA required document, serves as the hazardous material shipping paper, a DOT required document. Therefore anytime hazardous waste is offered for transportation by a public route, a DOT-EPA "joint jurisdiction" condition is created, causing the RCRA hazardous waste generator personnel that signs the manifest to also be identified as a DOT hazmat employee. Thus triggering a 49 CFR DOT training requirement as well as a 40 CFR RCRA training requirement for that individual.
Every DOT hazardous materials training course provided to hazmat employees must cover or include the following four topics at a minimum: General Awareness/Familiarization; Function-Specific Requirements; Related Safety; and Security Awareness. The Security Awareness training component is specific to risks of terrorists utilizing hazardous materials as weapons of mass destruction during or in preparation of transportation events. DOT Training offered by The University of Findlay’s School of Environmental and Emergency Management (SEEM) capitalizes on the University’s extensive network of environmental, hazmat, emergency response, and security professionals in providing information that is relevant and timely in meeting the many challenges presented when shipping hazardous materials today.
Even though DOT Training is required once every three years, SEEM strongly recommends that responsible compliance and security personnel receive DOT Training every year. DOT regulations for shipping hazardous materials are amended at least two to three times a year by DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA). In addition there are multiple revisions necessitated by United Nation’s Recommendations from the Committee of Experts on Dangerous Goods, that addresses international and global hazardous material shipping concerns.
Meeting Regulatory Requirements
Shippers and transporters of hazardous materials, and facilities that receive hazardous materials, are required to provide DOT Training to their hazmat employees, in accordance with 49 CFR Part 172 Subpart H, and as specified in Section 172.702. Shippers include industrial manufacturers/hazardous waste generators, commercial business, state and federal facilities. In addition to hazardous waste, hazardous materials include chemical products and raw materials being shipped to the industrial manufacturer that will be the hazardous waste generator.
Hazmat employees include employees that directly affect hazardous materials transportation safety; and employees who load, unload or handle hazardous materials; and/or prepare hazardous materials for transportation. In addition to loading and unloading hazardous materials, common activities performed by hazmat employees include: completing and signing shipping papers/manifests; selecting packaging to be used for hazardous material shipments; package filling and closure; package marking, labeling, and placarding. Even though contractors may perform certain duties, compliance and training is the shippers responsibility and liability.
The DOT Training provided by SEEM better enables professional hazmat and security personnel to establish necessary hazmat training programs for hazmat employees at their shipper/receiver facility location. DOT Training Program Documentation is necessary in managing both corporate and personal liability risks in the event of a significant hazmat transportation event. SEEM Training Programs not only offer DOT Training Completion Certificates/Certification, but also provide Continuing Education Units (CEUs) necessary for professional credentials and re-certifications. The University of Findlay’s DOT Training Programs are beneficial to hazardous materials transportation corporations/transporters as well, even though hazmat endorsements are not provided for Commercial Drivers Licenses (CDLs). Transporter terminal locations will often cause the transportation company to take on the role of shipper as well as hazardous waste generator.
In-Plant Customization and Training
The DOT Training Programs offered by SEEM can be brought right to your shipping doorstep. The University of Findlay specializes in providing professional hazmat, health and safety training on-site at industrial plant locations – we bring the training to you! This is an increasingly attractive training option as the demand on compliance and security personnel’s time increases along with expenses associated with business travel.
In addition, all DOT Training Programs can be customized to meet your plant-specific needs and individual personnel training needs. Training manuals, training presentations, and training hours will be created to the hazmat client’s specifications. DOT Training can also be combined with RCRA Training, OSHA Training or other environmental compliance training, in order to meet multiple regulatory requirements with one training event at your location.
Open Enrollment Training
DOT Training offered by SEEM as Open Enrollment at The University of Findlay in Findlay, Ohio, includes DOT Hazardous Materials Transportation/Security Training, and DOT Refresher/Recurrent Training Courses. For more information on these Training Courses, Training Course Dates, and/or to register for any of these DOT Training Courses, please contact us.
| | DOT Project Summaries | | Emergency Response, OSHA Safety and DOT Safety Training | | Over the past 6+ years SEEM has designed and delivered training services for the Occupational Safety & Environmental Health department of a major state-supported university in the Upper Midwest. The program relates to university emergency response team (Technician-Level), annual ER Refresher, OSHA Hazardous Waste Site Worker, Incident Command and DOT training requirements. SEEM conducts this training on an annual basis in order to sharpen the skills of its campus response teams. The training is provided at the client’s campus, where spill response and emergency scenarios are customized to their facilities, organizational structure, potential risks, department of public safety needs and university power plant requirements. To date, over 1,100 certificates have been issued for successful completion of training through the offering of 70 individual classes to University employees. | | Emergency Response, OSHA Safety and DOT Safety Training for a Major University in Michigan | |
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