HazMat Transportation: Navigating Training Requirements
- Ron Gantt (Safety Compliance Management Inc.)
- Document ID
- American Society of Safety Engineers
- Professional Safety
- Publication Date
- June 2013
- Document Type
- Journal Paper
- 68 - 75
- 2013. American Society of Safety Engineers
- 1 in the last 30 days
- 54 since 2007
- Show more detail
A sense of duty compels safety professionals to identify and control hazards, as do many regulatory standards. Understanding what rules apply and in what situations can seem daunting. Prime examples are the rules and regulations regarding the transportation of HazMats and dangerous goods.
To the uninitiated, navigating through DOT’s Hazardous Materials Regulations (HMR), with its various requirements, special provisions and exceptions, may leave one feeling overwhelmed. Add to these mandates international regulations and standards, such as those from International Civil Aviation Organization (ICAO), International Air Transport Association (IATA) and International Maritime Organization (IMO), and the task seems even more challenging. The training requirements alone—identifying who needs training, what must be covered and how to best manage the program—can leave one frustrated.
Further raising the stakes is the fact that a minimum citation for a training violation is almost double the minimum for other violations, and maximum fines can reach into the hundreds of thousands of dollars for civil penalties, with the potential for criminal penalties, including prison time, for extreme violations (DOT, 2012). Furthermore, according to 49 CFR Section 171.1(g), violations can be com-pounded with each new day being a new violation. This can make failures to identify employees who need training costly.
Despite this, training violations remain among the 10 most frequently cited violations (DOT, 2012). This is partly because many agencies and groups monitor HazMat transportation. A non exhaustive list includes Pipeline and Hazardous Materials Safety Administration (PHMSA), Federal Aviation Administration, Federal Motor Carrier Safe-ty Administration, Federal Railroad Administration, U.S. Coast Guard, state transportation agencies such as Highway Patrol, international agencies and some local agencies. Governmental agencies on the periphery of HazMat transportation can have overlapping jurisdiction as well; EPA and its numerous state variations are a primary example (see the sidebar on p. 70).
Effective training is a pillar of successful safety programs. A study on the effectiveness of the California Injury and Illness Prevention Program (IIPP) regulations reported that training was the IIPP element most associated with a decreased injury rate (Mendeloff, Gray, Haviland, et al., 2011). Since training is such an important element of regulatory compliance and program effectiveness, safety professionals should strive not simply to meet minimum standards, but to identify areas where compliance can be leveraged into safety programs to prevent injuries and illnesses.
This article provides an introductory survey of training requirements found in the DOT HMR, as well as some international standards for the transportation of HazMats and dangerous goods. Suggestions for how these training programs can be managed and integrated into an organization’s broader training are provided as well.
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