Q: Our company ships hazardous materials. How do we identify which employees actually need hazmat training?
It’s vital that you make informed decisions as to which members of your team need training. Because non-existent or insufficient training is one of the most common violations cited by enforcement agencies, you need to ensure your company maintains a strong Dangerous Goods training program.
From a regulatory perspective, employees meeting the definition of a “hazmat employee” need to be trained in accordance with 49 CFR, Part 172, Subpart H, unless otherwise excepted. But determining which employees are required to meet those training standards can be tricky.
Mandatory for some, valuable for many
So, who needs training?
Staff members involved in packaging, labeling, or filling out the shipping paperwork? Obviously yes. Your accounting department? Probably not. What about your executive team? Your sales staff?
For me, the most direct way to tell whether training is mandatory is to ask whether someone is performing one or more of the pre-transportation functions defined in the 49 CFR (§171.8):
- Classifying a hazardous material
- Selecting, filling, closing, marking, or labeling a hazardous materials packaging
- Preparing a shipping paper or reviewing one for compliance
- Providing emergency response info
- Loading, segregating, or carrying hazardous materials in a freight container or transport vehicle
- Selecting, providing, or affixing placards for a freight container or transport vehicle
If they are engaging in any of those activities, training is required by law.
Even if training isn’t mandatory, there are valuable benefits to educating employees about the risks and regulations surrounding hazmat transportation.
Understandably, you might be hesitant to take employees away from operational tasks to participate in a training course. But just because individuals aren’t shipping hazardous materials themselves doesn’t mean they have no impact on the company’s hazmat shipping operations.
Training prevents costly mistakes
Consider just a couple of examples we’ve encountered where Dangerous Goods training may have proved valuable:
Example #1: Unaware of the extent to which lithium batteries are regulated, product development engineers were buying lithium metal and lithium ion cells online at the lowest cost—without regard to whether the cells had met UN testing standards. Unfortunately, lithium cells or batteries that have not met the appropriate tests in the UN Manual of Tests and Criteria are forbidden from transport, unless specifically approved by the US Department of Transportation.
By not verifying the quality of the supplier’s lithium cells, these product engineers are now in possession of un-shippable lithium batteries that are destined for disposal—a costly yet avoidable error.
Example #2: A company routes all their limited quantity hazmat shipments to ground transport. An overzealous sales member, who doesn’t know the difference between products that are regulated in transport and those that are not, promises a customer a delivery time that the shipping department cannot keep.
Had the sales team been better informed on their company’s Dangerous Goods transportation operations, this mistake could have been avoided.
A comprehensive hazmat training program is vital to helping your company maintain compliance with Dangerous Goods transportation regulations—and essential to avoid mistakes like the ones above.
Labelmaster Services can help your company develop such a training program—from creating customized eLearning training modules, to crafting and delivering a tailored classroom-style Dangerous Goods course to your staff. Call 800-578-4955 or 206-697-0560 (outside the U.S. and Canada), or email email@example.com to learn more.
Labelmaster Senior Consultant Mike Pagel will be happy to answer any of your questions about Dangerous Goods shipping and handling.