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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 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 UF 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. UF 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
UF 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.
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 UF cover the new
hazardous waste manifest form and manifesting requirements - effective
in 2006. The introductory and recurrent DOT training courses provided at
UF 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 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.
Open Enrollment Training
DOT Training offered 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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