DOT HM-181 Requirements: Are You in Compliance?
As a safety professional, it is difficult to keep up with changing OSHA regulations as well as environmental regulations that we may also have to monitor, especially when dealing with hazardous materials. Often, we overlook DOT requirements for those of us that ship or receive hazardous materials.
Also known as “dangerous goods,” hazardous materials are chemicals that pose a serious risk to health, safety, and property during transport from one location to another. These materials fall into nine classes of hazards that include explosives, corrosives, oxidizers, flammable liquids, and miscellaneous hazardous materials, among others. While many people think of toxic waste when they hear the term “hazardous materials,” many everyday things fall into the nine hazard classes, such as insecticides, cleaning supplies, aerosols, and used paint.
Department of Transportation (DOT), per 49 Code of Federal Regulations (CFR) part 172.704, states that an employer has a responsibility to provide and fully comply with hazardous material training. This responsibility is enforced with civil and criminal penalties, with a worst-case civil fine of $175,000 and a criminal penalty of 10 years imprisonment per violation.
The DOT does not review or certify training programs. A given employer is responsible for choosing the training program that provides the training needs of the employees. Safety professionals should carefully review the qualifications of any trainer and the associated training material. Employees are to be trained at least once every three years. Employers should be aware that any changes in hazardous materials and the related work conditions would likely require retraining. If new hazardous materials are being introduced, an employer should have additional hazardous material training conducted.
The employer is required to train any employee involved in the handling and shipping of hazardous materials. This would include:
- Employees working in the shipping area, who may be involved in preparing or transporting hazardous materials (labeling and/or marking packages),
- Forklift and heavy equipment operators who load or unload hazardous materials,
- Delivery drivers, and,
- Managers, supervisors, or clerks who act as the shipper or sign documents associated with hazardous materials (e.g., bills of lading, hazardous waste manifests).
Training must be thorough and assure comprehension through testing. The employer must do more than simply provide HM-181 training to employees. Employers must prove that the provided training answers the requirements for all hazardous material hazards affecting their employees. This includes:
General awareness/familiarization: General awareness and familiarization training is intended to raise the hazmat employees’ awareness of the HMR and the purpose and meaning of the hazard communication requirements. All hazmat employees must have this training.
Function-specific training: Function-specific training is intended to teach the necessary knowledge, skills, and abilities for an individual’s job function. This may include driver training, if applicable.
Safety Training: This training provides information concerning the hazards posed by materials in the workplace and personal protection measures. The training may include basic emergency response procedures but is not intended to satisfy the requirements of 29 CFR 1910.120.
Security Training: Each hazmat employee must receive security awareness training. This training must include an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. New hazmat employees must receive this training within 90 days of employment.
Safety professionals are encouraged to review in detail this material for any changes that may impact their specific work environment or culture.
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