{"operation":"document","citation":"PHMSA Guidance, Guide to Developing a Hazmat Training Program","title":"Guide to Developing a Hazmat Training Program","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-10-01","effective_on":"2018-10-01","summary":"Guide to Developing a Hazmat Training Program Document Guide-to-Developing-a-Hazmat-Training-Program-0173-1018.pdf (6.39 MB) This guide explains the training requirements in the Hazardous Materials Regulations, identifies those employees who must be trained, and provides a tool to help hazmat employers determine what type of training and training environment may be best for their employees. Issued Date: Monday, Octob","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-guide-developing-hazmat-training-program-1b1c28a1.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-guide-developing-hazmat-training-program-1b1c28a1.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-guide-developing-hazmat-training-program-1b1c28a1","source_url":"https://www.phmsa.dot.gov/training/hazmat/guide-developing-hazmat-training-program","body":"Guide to Developing a Hazmat Training Program\n\nDocument\n\n Guide-to-Developing-a-Hazmat-Training-Program-0173-1018.pdf (6.39 MB)\n\n        This guide explains the training requirements in the Hazardous Materials Regulations, identifies those employees who must be trained, and provides a tool to help hazmat employers determine what type of training and training environment may be best for their employees.\n\n          Issued Date: Monday, October 1, 2018\n\n<<<PAGE 1>>>\n\nGUIDE TO DEVELOPING A\nHAZMAT TRAINING PROGRAM\nGeneral Awareness, Function-Specific, Safety,\nSecurity Awareness, and In-Depth Security Training.\nWWW.PHMSA.DOT.GOV\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n1\n\n<<<PAGE 2>>>\n\nACKNOWLEDGEMENTS\nThis guidance has been prepared based on a partnership agreement between the U.S. Department of Transportation,\nPipeline and Hazardous Materials Safety Administration (PHMSA) and the Dangerous Goods Advisory Council (DGAC)\nwith input from the Dangerous Goods Symposium for Instructors and the hazmat community.\n\n<<<PAGE 3>>>\n\nTABLE OF CONTENTS\nPURPOSE\nHAZMAT REGULATORY REQUIREMENTS\nSCOPE OF THE HAZARDOUS MATERIALS REGULATIONS 6\nTHE HAZARDOUS MATERIALS REGULATIONS’ TRAINING REQUIREMENTS 7\nTHE FIVE TYPES OF REQUIRED TRAINING 8\nRECORDKEEPING REQUIREMENTS 8\nOTHER DOMESTIC AND INTERNATIONAL TRAINING REQUIREMENTS 9\nHOW TO DEVELOP A TRAINING PROGRAM\nDETERMINE WHO ARE YOUR HAZMAT EMPLOYEES 10\nDETERMINE WHAT YOUR HAZMAT EMPLOYEES NEED 11\nASSESS YOUR TRAINING OPTIONS 12\nADVANTAGES AND DISADVANTAGES OF TRAINING OPTIONS 13\nEVALUATE THE EFFECTIVENESS OF YOUR TRAINING 15\nIMPLEMENTING BEST PRACTICES AND GUIDELINES\nDEVELOP A SAFETY CULTURE 16\nDESIGNATE A TRAINING COORDINATOR 17\nIMPLEMENT A PLANNING PROCESS 18\nIMPLEMENT A CONSISTENT PROCESS FOR RECORDKEEPING 19\nDEVELOP A TRAINING CURRICULUM 20\nCHECKING YOUR PROGRAM FOR ACCURACY\nDO YOU HAVE A TRAINING POLICY? 22\nWHAT TYPE OF TRAINING IS PROVIDED? 23\nWHERE IS THE TRAINING PROVIDED? 24\nIS YOUR FUNCTION-SPECIFIC TRAINING ADEQUATE? 25\nRESOURCES FOR MORE INFORMATION\nLETTERS OF INTERPRETATION 26\nTRAINING MATERIALS AND PUBLICATIONS 26\nSEMINARS, WORKSHOPS, AND SPECIAL EVENTS 26\nHAZMAT INFO-LINE 26\nGLOSSARY\n\n<<<PAGE 4>>>\n\n\n\n<<<PAGE 5>>>\n\nPURPOSE\nThe transportation of hazardous materials (hazmat)\nunderpins the American economy and our way of life.\nWe use oil and natural gas to heat and cool homes and\nbusinesses, produce electricity, and provide raw materials\nfor plastics, fibers, paints, and other essential products.\nWe rely on chemicals to clean our water, fuel cars,\nconstruct buildings, fertilize crops, create medicines,\nand manufacture clothing and many other essential\ncommodities. While hazmat plays a critical role in our\ndaily lives, the transportation of hazmat introduces some\ninherent risks to the public, the environment, and property\nthat must be appropriately managed.\nHazmat transportation is a process that involves people\nperforming functions related to handling, packaging,\nstoring, moving, loading and unloading of hazmat, and\nresponding to emergency situations while such materials\nare in transportation. It includes employees responsible\nfor the safe transportation of hazmat. The process also\nincorporates functions to design, manufacture, fabricate,\ninspect, mark, maintain, recondition, repair, or test a\npackage, container or packaging component used in\ntransporting hazmat. With such a complex process, the\nU.S. Department of Transportation (DOT) has identified\nhuman error as a contributing cause for most hazmat\ntransportation incidents.\nHuman error may result from a variety of factors\nincluding:\n•\n•\n•\n•\n•\n•\nLack of knowledge leading to the mishandling of\nhazmat\nLack of knowledge leading to undeclared shipments\nLack of awareness that hazmat is present\nFailure to follow established safety procedures\nLack of understanding of one’s role during an\nincident should one occur\nLack of knowledge on how to respond to an incident\nshould one occur.\nHazmat incidents caused by human error can be reduced\nthrough the implementation of an effective training\nprogram. An effective training program is a systematic\nmethod for providing training, which includes tests and\nquizzes. It may consist of materials such as handouts,\noverheads, videos, and exercises, as well as, interactive\ncomputer-based training, tests and quizzes and, where\nthere is an instructor, the instructor’s notes or course\noutline. The training program may be a tutored or self-\nstudy course. The training provider may be the hazmat\nemployer or an independent training provider.\nAn effective training program:\n•\n•\n•\n•\n•\n•\n•\n•\nDevelops a strong safety culture\nHeightens employee safety by helping employees\nprotect themselves\nImproves a company’s effectiveness, efficiency,\nand productivity\nIncreases employee skills\nMay prevent regulatory sanctions\nAids in ensuring safe and secure shipment of hazmat\nReduces likelihood of catastrophic event such as\nfire aboard aircraft\nProvides employees with understanding of why\ncompliance and safety are necessary.\nThis guidance document explains the training\nrequirements in the Hazardous Materials Regulations\n(HMR), identifies those employees who must be trained,\nand provides a tool to help hazmat employers determine\nwhat type of training and training environment may be\nbest for their employees.\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n5\n\n<<<PAGE 6>>>\n\nHAZMAT REGULATORY REQUIREMENTS\nSCOPE OF THE HAZARDOUS MATERIALS REGULATIONS\nThe HMR (49 CFR Parts 100- 185), issued by the Department of Transportation’s Pipeline and Hazardous Materials\nSafety Administration (PHMSA) under authority of the Federal hazardous materials transportation law (49 U.S.C. 5101 et\nseq.), establish requirements governing the commercial transportation of hazmat by highway, rail, vessel, and air.\nUnder the HMR, hazmat are categorized by analysis and experience and assigned hazard classes and packing groups\nbased upon the risks they present during transportation. The HMR specify appropriate packaging and handling\nrequirements for hazmat, and require a shipper to communicate the material’s hazards through use of shipping papers,\npackage marking and labeling, and vehicle placarding. The HMR also require shippers to provide emergency response\ninformation applicable to the specific hazard or hazards of the material being transported.\n6\n\n<<<PAGE 7>>>\n\nTHE HAZARDOUS MATERIALS REGULATIONS’ TRAINING REQUIREMENTS\nThe HMR mandate training requirements for persons who prepare hazmat for shipment or who transport hazmat\nin commerce. The intent of the regulations is to ensure that each hazmat employee is familiar with the HMR, is able\nto recognize and identify hazmat, understands the specific HMR requirements applicable to the functions he or she\nperforms, and is knowledgeable about emergency response, self-protection measures, and accident prevention methods.\nThe regulations are performance based to provide a baseline set of training requirements while acknowledging the need\nfor flexibility due to the diversity of the hazmat workforce.\nTraining requirements are located in Subpart H of Part 172 of the HMR. The training requirements apply to hazmat\nemployers and hazmat employees as defined in §171.8. The HMR require all hazmat employees to be trained including\nhazmat employers with direct supervision of hazmat transportation functions. Hazmat employer and hazmat employee\nare defined as follows:\nHAZMAT EMPLOYER means a person who uses one or more employees in connection with:\n•\ntransporting hazmat in commerce;\n•\ncausing hazmat to be transported or shipped in commerce; or\n•\nrepresenting, marking, certifying, selling, offering, reconditioning, testing, repairing, or modifying packagings\nas qualified for use in the transportation of hazmat.\nThe term “hazmat employer” also includes any department, agency, or instrumentality of the United States, a State, a\npolitical subdivision of a State, or Native American Indian tribe engaged in offering or transporting hazmat in commerce.\nThis term includes an owner-operator of a motor vehicle that transports hazmat in commerce.\nHAZMAT transportation safety including:\nEMPLOYEE means a person who is employed by a hazmat employer and who directly affects hazmat\n•\nan owner-operator of a motor vehicle that transports hazmat;\n•\na person (including a self-employed person) who:\n| loads, unloads, or handles hazmat;\n| tests, reconditions, repairs, modifies, marks, or otherwise represents packagings as qualified for use in\nthe transportation of hazmat;\n| prepares hazmat for transportation;\n| is responsible for the safety of transporting hazmat; or\n| operates a vehicle used to transport hazmat.\nTraining must be completed within 90 days of the first day of employment or the first day of a change in job function.\nUntil training is completed, a hazmat employee must be directly supervised by a person who has been trained. Further,\neach hazmat employee must be provided with recurrent training at least once every three years. Each hazmat employee\nmust be tested upon completion of training. Training may be provided directly by the hazmat employer or by other\npublic or private sources. Regardless of who provides the training, the hazmat employer is responsible for ensuring\nthat appropriate testing occurs and that the training is effective, appropriate, and successful in achieving the intended\nobjectives of providing employees with the knowledge and skills necessary to perform their job functions safely.\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n7\n\n<<<PAGE 8>>>\n\nTHE FIVE TYPES OF REQUIRED TRAINING\nGENERAL AWARENESS/FAMILIARIZATION TRAINING is training that provides familiarity with\nthe general requirements of the HMR, and enables the hazmat employee to recognize and identify hazmat. All hazmat\nemployees must receive general awareness training.\nFUNCTION-SPECIFIC TRAINING is training that provides a detailed understanding of HMR requirements\napplicable to the function(s) performed by the hazmat employee. Each hazmat employee must be trained on the specific\nfunctions they are required to perform.\nSAFETY TRAINING is training that covers the hazards presented by hazmat, safe handling, emergency response\ninformation, and methods and procedures for accident avoidance. All hazmat employees must receive this training.\nSECURITY AWARENESS TRAINING is training that provides a general understanding of the security risks\nassociated with hazmat transportation and the methods designed to enhance transportation security. This training\nshould include methods on how to recognize and respond to possible security threats. All hazmat employees must receive\nthis training.\nIN-DEPTH SECURITY TRAINING is training that provides a detailed understanding of a company’s security\nplan including company security objectives, specific security procedures, employee responsibilities, actions to take in the\nevent of a security breach and the organizational security structure. This training must be provided to hazmat employees\nwho handle or perform regulated functions related to the transportation of the materials covered by the security plan or\nwho are responsible for implementing the security plan.\nRECORDKEEPING REQUIREMENTS\nThe hazmat employer is responsible for maintaining training records for each hazmat employee. These records must be\nkept for the duration of the three-year training cycle while the hazmat employee is employed and for 90 days after the\nemployee leaves employment. Training records must be made available by the employer for audit and review by regulatory\nauthorities upon request.\nTraining records must include the following:\n•\n•\n•\n•\n•\nThe hazmat employee’s name\nThe most recent training completion date\nA description of, copy of, or reference to training materials used to meet the training requirements\nThe name and address of the person providing the training\nA certification that the person has been trained and tested as required\nCertification that the hazmat employee has been trained and tested shall be made by the hazmat employer or a\ndesignated representative. An example training record can be found in the Implementing Best Practices and Guidelines\nsection on p. 19.\n8\n\n<<<PAGE 9>>>\n\nOTHER DOMESTIC AND INTERNATIONAL TRAINING REQUIREMENTS\nEmployers should be aware that the HMR recognizes that other domestic and international agencies and organizations\nalso have training requirements. For example, the Federal Aviation Administration prescribes training requirements\nfor air carriers in the 14 CFR. Additionally, the International Maritime Dangerous Goods Code for vessel shipments;\nTransport Canada TDG Regulations; and the International Civil Aviation Organization (ICAO) Technical Instructions for\nair shipments also prescribe specific training requirements that are important because the HMR authorizes compliance\nwith these regulations.\nTherefore, depending on a company’s operations, other training requirements in addition to the HMR may apply.\nRelevant agencies and organizations may include:\n•\n•\n•\n•\n•\n•\n•\n•\n•\nUnited States Federal Aviation Administration (FAA)\nUnited States Federal Motor Carrier Safety Administration (FMCSA)\nUnited States Federal Railroad Administration (FRA)\nUnited States Coast Guard (USCG)\nUnited States Occupational Safety and Health Administration (OSHA)\nUnited States Environmental Protection Agency (EPA)\nTransport Canada TDG regulations (TDG)\nInternational Maritime Organization (IMO)\nInternational Civil Aviation Organization (ICAO)\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n9\n\n<<<PAGE 10>>>\n\nHOW TO DEVELOP A TRAINING PROGRAM\nDETERMINE WHO ARE YOUR HAZMAT EMPLOYEES\nSafe transportation of hazmat depends on proper preparation of the material for shipment and safe handling of the\nmaterial while it is being transported. Each hazmat employee must be aware of the hazards of such materials, their\npotential for causing incidents and accidents, and how they should be safely prepared and transported.\nThe HMR require all hazmat employees to be trained, including those with hazmat responsibilities including pre-\ntransportation functions (see Glossary or 49 CFR §171.8) and those who supervise hazmat employees. For example,\na hazmat employee may be a person (including a self-employed person or an owner-operator of a motor vehicle) who:\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\nDetermines the hazard class of hazmat\nSelects a hazmat packaging\nPlaces warning signs, blocks wheels, and sets brakes on tank cars placed for loading or unloading with closures\nopen\nFills or loads a hazmat packaging\nSecures closures on filled hazmat packages or containers\nMarks a package to indicate that it contains a hazmat\nLabels a package to indicate that it contains a hazmat\nPrepares a hazmat shipping paper\nProvides and maintains hazmat emergency response information\nReviews hazmat shipping papers to verify compliance with the HMR or international equivalents\nFor persons importing hazmat into the United States, provides the shipper with information as to the requirements\nof the HMR that apply to the shipment of the material while in the United States\nCertifies that hazmat is in proper condition for transportation in conformance with the requirements of the HMR\nBlocks and braces hazmat packages in a freight container or transport vehicle\nSegregates hazmat packages in a freight container or transport vehicle from incompatible cargo\nSelects, provides, or affixes placards for a freight container or transport vehicle to indicate that it is carrying hazmat\nLoads or unloads hazmat for the purpose of transportation\nTests, reconditions, or repairs hazmat packaging\nOperates a vehicle used to transport hazmat\n10\n\n<<<PAGE 11>>>\n\nDETERMINE WHAT YOUR HAZMAT EMPLOYEES NEED\nAs previously mentioned, HMR training requirements are performance based to provide flexibility regarding training\nformat and delivery. Training may be provided directly by the hazmat employer or by independent training providers.\nTherefore, hazmat employers have a variety of training options available.\nThe hazmat employer is responsible for selecting training that meets company safety goals and the HMR requirements.\nThe process may begin by conducting a needs assessment based on a thorough understanding of your company’s\noperations and its hazmat employees’ responsibilities, knowledge and capabilities.\nYou may want to begin with these questions:\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\nWhat hazmat/wastes does your company handle and which hazards do they represent? For example, do your\nhazmat employees handle hazmat such as infectious substances and lithium batteries?\nWhat quantities do you ship and how frequently? For example, do you ship bulk, non-bulk, excepted quantities, or\nsmall quantities?\nWhat modes of transport do you use?\nAre there materials that your employees may not be aware are hazmat and are subsequently being shipped\nundeclared? Examples include paint, perfume, batteries, aerosols, and fireworks.\nWhere do you transport hazmat (i.e., domestic or international locations)?\nDo company accident or injury rates indicate additional training is necessary? If so, in what areas?\nWhat regulations does the training need to cover?\nWhat are the job descriptions/functions of your hazmat employees?\nHave your hazmat employees been previously trained?\nAre your hazmat employees trained in all aspects of the function(s) they are performing? For example, are your\nemployees responsible for shipper certification, i.e., trained in each aspect of the hazmat shipping that they are\ncertifying, such as packaging or package closure requirements?\nHave any responsibilities changed?\nHas the company’s operations changed?\nWhat languages need to be addressed?\nAre your employees aware of incident reporting requirements?\nHas anything else changed?\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n11\n\n<<<PAGE 12>>>\n\nASSESS YOUR TRAINING OPTIONS\nAfter the needs assessment is complete, it is time to select a training tool. Potential selection criteria are content, method\nof delivery, and instructor qualifications.\nCONTENT should be easy to understand and appropriate for the audience. Sufficient time should be allocated to cover\nthe subject matter, and techniques should be used to ensure that students comprehend and retain the material presented.\nA few questions hazmat employers might ask when assessing content include:\n•\n•\n•\n•\n•\n•\n•\n•\nIs the time allotted for training sufficient for employee comprehension?\nIs the information presented clearly and accurately and in a manner that can be understood by employees of\nvarying literacy and language skills?\nDoes the training use repetition to confirm that key points are understood?\nDoes the training use exercises, questions, or other mechanisms to ensure an understanding of what has been\ntaught?\nIs the information presented in a logical manner?\nIs comprehension tested?\nIs a test provided that allows the hazmat employee to demonstrate that they have satisfactorily completed training?\nIs there a follow-up support system? If so, what is it and does this system meet the need?\nMETHOD OF DELIVERY is another consideration for your training program. For purposes of this guidance,\ntraining options have been broken down into four delivery methods:\n•\n•\n•\n•\nWeb-based\nComputer-based\nClassroom\nHands-on/Mentor training\nEach delivery method has advantages and disadvantages.\nINSTRUCTOR QUALIFICATIONS are an important element of an effective training program. Hazmat\ninstructors have varying degrees of subject matter expertise and teaching skills. In addition to understanding the subject\nmatter, instructors should understand the best method of delivery for the given audience.\n12\n\n<<<PAGE 13>>>\n\nADVANTAGES AND DISADVANTAGES OF TRAINING OPTIONS\nWEB-BASED TRAINING\nADVANTAGES DISADVANTAGES\nProvides standardized training ensuring a consistent message Decreases the time employees are out of the office Allows for quick updates for rapidly changing material Bandwidth limitations can place constraints on certain media\ntypes\nHazmat employees must be self-directed and comfortable using\nthe web\nHazmat employees may be distracted or interrupted\nTraining is more accessible to a larger audience Difficult to provide opportunities for hands-on experience\nCost effective way to refresh existing training Training is more convenient for employees -- it is available\nanytime, anywhere No travel costs No costs associated with obtaining new media updates Some may find it difficult to engage and retain\nLimited interaction with an instructor\nDifficult to assess employee progress in real time\nCompatible equipment may not be available\nCOMPUTER-BASED TRAINING\nADVANTAGES DISADVANTAGES\nWhen there is a lot of video or complex graphics, computer-based\ntraining can ease download times and improve operations Offers flexibility for the end-user; hazmat employees can simply\nload and run the training at their convenience Cost effective way to refresh existing training Requires self-direction\nHazmat employees may be distracted or interrupted\nIt is difficult to provide opportunities for hands-on experience\nTraining is more accessible to a larger audience Minimal interaction with an instructor or subject matter expert\nHazmat employees can proceed at their own pace No travel costs Information can become outdated\nPossible higher cost to update\nSome may find it difficult to engage and retain\nCompatible equipment may not be available\nDifficult to assess employee progress in real time\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n13\n\n<<<PAGE 14>>>\n\nCLASSROOM TRAINING\nADVANTAGES Provides an instructor and a structured approach to teaching Allows for real-time discussion and provides interaction that\nisn’t easily duplicated even with the most advanced technology\nAllows for constructive team building Personalized assistance from the instructor can address\nindividual student needs\nLeverages instructor skills and experience Easy to confirm whether hazmat employees have taken the\ncourse\nEasy to use evaluation tools to confirm that learning has\noccurred\nOpportunity to customize training to meet employer needs and\nrequirements\nHANDS-ON/MENTOR TRAINING\nADVANTAGES Simulates the job Provides hands-on experience allowing the hazmat employee to\nintegrate theory and practice Allows the employee to use critical thinking skills and problem-\nsolving processes that incorporate professional knowledge\nProvides a sense of urgency to develop alternatives and make\ndecisions under pressure without the possibility of consequences Mentors gain more credibility with the employee since they have\nspecific experience relating to the subject being taught Procedural and policy gaps are identified\nMay avoid comprehension problems related to literacy/language\ndeficiencies\n14\nDISADVANTAGES\nPotential personality differences between the trainer and the\nhazmat employees\nTrainees can dictate the pace of training, leaving some students\nbehind, and others bored with a pace that is too slow for them\nDifficult to guarantee outcomes\nScheduling based on trainer or facility availability, not employee\nneeds\nCosts for travel, training, and the instructor\nDISADVANTAGES\nCan be high cost, high overhead\nVariables differ, so it’s difficult to guarantee outcomes\nTiming based on mentor and/or facility availability, not\nnecessarily employee needs\nPotential personality differences\nA mentor must be available and capable of training\n\n<<<PAGE 15>>>\n\nEVALUATE THE EFFECTIVENESS OF YOUR TRAINING PROGRAM\nIt is important to evaluate the effectiveness of the selected training tools against your expectations. Conducting an\nevaluation allows you to improve the future planning and implementation of a training program, determine if training\nobjectives have been achieved, and proactively facilitate any necessary adjustments.\nWhen conducting the evaluation, a few helpful questions include:\n•\nDid the employee believe the training was effective and useful?\n•\nWhat were the expectations of the training? Were these expectations met?\n•\nAfter the training, is the employee proficient in performing job duties and responsibilities?\n•\nDoes the employee appear to need further training? If so, what functions need additional focus? Is this the result of\na deficiency in training?\nMany techniques and tools can be used to evaluate training programs. A few methods of evaluating training are:\n•\nStudent opinion: Using employee feedback to help determine effectiveness of the training program including\nidentifying how to improve course content and delivery\n•\nSupervisors’ observations: Using supervisor observations to assess an employee’s performance both before and\nafter the training\n•\nOn-the-job improvements: Assessing whether changes occur in job performance that result in changes in accident\nrates, injury rates, or penalties\nRegardless of the approach, if done correctly, you can use information derived from evaluations to help determine\nwhether training is effective and how to apply future training resources.\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n15\n\n<<<PAGE 16>>>\n\nIMPLEMENTING BEST PRACTICES AND GUIDELINES\nDEVELOP A SAFETY CULTURE\nThe HMR requires training for all hazmat employees; however, your training program should not stop once you have met\nthe HMR requirements. You and your managers should work with employees to develop a supportive safety culture that\nencourages training as a continuous learning process.\nYou may want to consider implementing some or all of these measures:\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\nVisible promotion of a safety culture driven by top management\nEstablish accountability for safety that begins with individual employees and includes all management layers\nEncourage employees to report safety issues or problems without fear of retribution or retaliation\nEncourage employees to identify new, improved ways to accomplish safety goals\nMonitor and evaluate employees as they perform their hazmat functions\nCorrect potential issues as they are identified\nProvide opportunities for additional training\nPeriodically reinforce safe practices through safety meetings\nAssess company safety performance through audits\nConsider implementing a monthly 10% hazmat inventory program wherein 10% of a company’s hazmat is spot\nchecked for proper packaging and hazmat communication each month. Implementing such a practice can help\ndetect potential errors\nKeep employees informed of assessments and results\nReview the results of incidents and inspections\nRegularly review regulatory changes and/or changes in company operations\nDeveloping a safety culture is a continuous process, and the rewards are real. Employees take ownership of the\noperations for which they are responsible and share responsibility equally with management for the overall safety of the\ncompany. Enhanced safety measures help to reduce the cost of doing business by reducing accidents, decreasing workers’\ncompensation claims, and providing a more effective and targeted use of resources. Thus, companies and individuals\nbecome more competitive while protecting people, property, and the environment.\n16\n\n<<<PAGE 17>>>\n\nDESIGNATE A TRAINING COORDINATOR\nIt is your responsibility to select training options that meet the requirements of the HMR and the needs of your hazmat\nemployees. This can be a challenging task, but it is extremely critical to ensuring that the training program you provide is\neffective and successful.\nOne way to manage hazmat training is to designate one or more employees as training coordinators. Suggested\nqualifications for training coordinators include:\n•\nKnowledge of the HMR as they apply to company operations\n•\nThe ability to monitor and understand regulatory changes as they develop\n•\nKnowledge of how to establish and manage a training program\n•\nExperience in one or more of the hazmat duties being performed\nOnce a training coordinator(s) is in place, he or she can guide the training and development of each hazmat employee.\nSuggested responsibilities include:\n•\nArranging for newly trained employees to be evaluated upon completion of a training program and periodically\nthereafter\n•\nDetermining training needs for incumbents and assessing training options\n•\nConsulting with other industry professionals on the best quality training available\n•\nInstituting formal training evaluation programs and providing feedback to training providers\n•\nCommunicating on the status of training with management\n•\nProviding feedback to training providers\n•\nMaintaining training records in accordance with the HMR\nA committee of trained hazardous materials employees may be established to provide guidance and assistance to the\ntraining coordinator. Examples of potential committee responsibilities may include identifying training needs and\nevaluating the effectiveness of training.\nTraining Coordinators often use checklists to record their progress during the development of a training program.\nExamples of these checklists can be found in the Checking Your Program For Accuracy section on p. 22.\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n17\n\n<<<PAGE 18>>>\n\nIMPLEMENT A PLANNING PROCESS\nImplementing a planning process can help you develop a consistent approach for managing training needs. An example\nplanning framework is provided below to assist you in this process. The framework is not intended to be exhaustive or all-\ninclusive, it is intended to help identify elements that could be considered.\nDEFINE OBJECTIVES\nExample Objective:\nDevelop properly trained hazmat employees to meet\nregulatory requirements for training, develop an educated\nworkforce, improve safety, and minimize the potential\nnegative impacts of hazmat on life, property, and the\nenvironment.\nDEFINE GOALS\nExample Goals:\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\nReduce incidents and accidents\nHelp employees protect themselves and the\nenvironment\nImprove a company’s effectiveness, efficiency, and\nproductivity\nDevelop a strong safety culture\nPrevent regulatory sanctions\nHeighten employee safety\nIncrease employee skills\nDecrease property damage costs\nHelp employees identify when hazmat are present\nIncrease productivity\nIMPLEMENT A TRAINING FRAMEWORK\nExample Framework:\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\nDemonstrate support from all levels of leadership\nIdentify point of contact(s) to manage training and\ncoordinate internally, as appropriate\nImplement accountability\nUnderstand employee responsibilities, the tools they\nuse, and company operations\nUnderstand status of training to date\nConduct a needs assessment to determine what\ntraining is needed\nPrioritize training needs\nAssess the landscape of available training tools\nand determine which tools meet the needs of the\norganization and its employees\nExecute training\nEvaluate training\nMaintain accurate training records to include:\n| The hazmat employee’s name\n| The most recent training completion date\n| A description of, copy of, or reference to\ntraining materials used to meet the training\nrequirements\n| The name and address of the person\nproviding the training; and a certification\nthat the person has been trained and tested\nas required\nContinuously improve the training program, as\nnecessary\n18\n\n<<<PAGE 19>>>\n\nIMPLEMENT A CONSISTENT PROCESS FOR RECORDKEEPING\nThe recordkeeping requirements in the HMR specify the content and retention rate of training records for each hazmat\nemployee, but do not specify the format for each record. Below is a sample training record to illustrate what a it may look\nlike.\nHAZMAT EMPLOYEE TRAINING RECORD\nDescription, Copy, and Location of Training Hazmat Training Introduction Video Hazmat Transportation Training Modules (On-line) Description, Copy, and Location of Training Cylinder Requalification Instruction Book Performance demonstration of Packaging, Marking and Labeling\nChecklist of tasks performed attached to this training record Description, Copy, and Location of Training Personal Safety Information Book Description, Copy, and Location of Training Hazmat Transportation Security Awareness Training Module\n(On-line)\nDescription, Copy, and Location of Training Company Security Plan and Risk Guidelines Binder General Awareness / Familiarization Training\nTrained By Training Officer\nJanet Training Officer\nJanet Function-Specifc Training\nTrained By Supervisor Dan Supervisor Dan Safety Training\nTrained By Supervisor Dan Security Awareness Training\nTrained By Training Officer\nJanet In-Depth Security Training\nTrained By Supervisor Dan Date Trained July 14, 2017 July 14, 2017 Test / Score\nNo Test\nOn-line Test; 95%\nDate Trained July 21, 2017 July 21, 2017 Test / Score\nWritten Test; 98%\nLive Demonstration\nTest; 100%\nDate Trained July 14, 2017 Test / Score\nWritten Test; 100%\nDate Trained July 28, 2017 Test / Score\nOn-line Test; 90%\nDate Trained July 28, 2017 Test / Score\nVerbal Test; Passed\nI certify that the hazmat employee identified on this training record has been trained and tested as required by the Hazardous\nMaterials Regulations, 49 CFR Part 172 Subpart H.\nEmployee Name: ______________________________ Signed:______________________________\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n19\n\n<<<PAGE 20>>>\n\nDEVELOP A TRAINING CURRICULUM\nThe HMR mandate five types of training. The HMR do not prescribe in detail what topics to address during each type of\ntraining. To assist in evaluating your company’s training needs, a list of the types of training with possible curriculums is\nprovided here. These lists are not intended to be exhaustive or all inclusive.\nGENERAL AWARENESS/FAMILIARIZATION provides hazmat employees with familiarity with the\nrequirements of the Hazardous Materials Regulations and enables hazmat employees to recognize and identify hazmat.\nAll hazmat employees are required to have general awareness/ familiarization training. This training typically provides a\nbasic understanding of:\n•\nThe Identification of Hazardous Materials\n•\nShipping Papers\n•\nThe Hazard Classification System\n•\nSegregation\n•\nHow to Use the Hazardous Materials Table\n•\nUnderstanding of the HMR Training Requirements\n•\nPackaging\n•\nRequirements for Incident Reporting\n•\nMarkings and Labels\n•\nSecurity\n•\nPlacards\nFUNCTION-SPECIFIC provides hazmat employees a detailed study of the requirements of the regulations\napplicable to the function(s) for which the person is responsible. Training needs will depend on the company operations\nand the hazmat employee’s responsibilities. Your responsibility is to identify the specific topics and extent to which topics\nare covered to meet your employees’ needs.\nExamples of function-specific topics are included within the Function-Specific Knowledge Checklist on p. 25.\n20\n\n<<<PAGE 21>>>\n\nSAFETY TRAINING covers the hazards presented by hazmat, safe handling, emergency response information, and\nmethods and procedures for accident avoidance. Training that meets EPA and OSHA regulations may be acceptable in\nmeeting the HMR. All hazmat employees are required to have safety training. Topics may include:\n•\nEmergency Response Information\n•\nRespiratory Protection\n•\nEmergency Response Telephone Numbers\n•\nFire Protection\n•\nMeans of Egress\n•\nFire Brigades\n•\nEmployee Emergency Plans and Fire Prevention Plans\n•\nPortable Fire Extinguishers\n•\nGeneral Safety and Health Provisions\n•\nFixed Extinguishing Systems\n•\nEmployee Emergency Action Plans\n•\nFire Detection Systems\n•\nBulk Delivery and Mixing Vehicles\n•\nEmployee Alarm Systems\n•\nContract Employer Responsibilities\n•\nMaterials Handling and Storage\n•\nMechanical Integrity\n•\nMoving the Load\n•\nNew Technology Programs\n•\nCrawler Locomotives and Truck Cranes\n•\nPersonal Protective Equipment\n•\nElectrical Safety-Related Work Practices\n•\nHazardous Waste Operations and Emergency\nResponse\n•\nConfined and Enclosed Spaces\n•\nPrecautions Before Entering\nSECURITY AWARENESS TRAINING provides hazmat employees with a general understanding of the\nsecurity risks associated with hazmat transportation and the methods designed to enhance transportation security. All\nhazmat employees are required to have security awareness training. Examples of subjects that could be included are:\n•\nRegulatory Requirements\n•\nPotential Threats\n•\nPotential Targets\n•\nPrevention Tools\nIN-DEPTH SECURITY TRAINING directly relates to the required company security plan. Specific content is\ndependent upon the company security plan and employee responsibilities. Hazmat employees are required to receive\ntraining commensurate with their responsibilities. Training must include:\n•\nSecurity Objectives\n•\nSpecific Security Procedures\n•\nEmployee Responsibilities\n•\nActions to Take in the Event of a Security Breach\n•\nOrganizational Security Structure\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n21\n\n<<<PAGE 22>>>\n\nCHECKING YOUR PROGRAM FOR ACCURACY\nDO YOU HAVE A TRAINING POLICY?\nThe hazmat employer is responsible for selecting training that meets company safety goals and the HMR requirements.\nAlthough not required by the HMR, many companies establish training policies or standard operating procedures to\nhelp with decision-making. Checklists can be used as tools to assist with understanding the status of training efforts and\ndecision-making.\nBelow is an example of a checklist that can help you to identify elements of your training policy. Rows have been left blank\nso that you can identify criteria not listed that is included in your company training policy.\nTRAINING POLICY CHECKLIST YES NO\nDo you have a training policy? If yes, what does it include?\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\nPurpose and scope A definitions section Identification of employees that require training A list of employee functions and responsibilities Identification of the type of training required Initial training requirements Recurrent training requirements Function-specific or company-specific Testing (pass/fail) requirements Record keeping requirements Certification of training requirements Training as needed (i.e., when regulations are updated or issued) Training every year Training every 2 years Training every 3 years □ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n22\n\n<<<PAGE 23>>>\n\nWHAT TYPE OF TRAINING IS PROVIDED?\nBelow is an example of a checklist to help you determine what additional training your employees might need. Rows have\nbeen left blank so you can identify topics not listed that are important to your company.\nTRAINING PROGRAM CHECKLIST YES NO\nWhat type of training is provided to your employees?\n•\nClassroom (In-house or external) •\nComputer-based •\nWeb-based •\nHands-on/Mentor What topics are included in your program?\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\n•\nGeneral Awareness Classification Documentation Packaging Marking Labeling Placarding Loading & Unloading (non-bulk) Loading & Unloading (bulk) Blocking & Bracing Security Awareness In-Depth Security Awareness Safety Segregation Incident Reporting Operations Packaging □ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\n□ □\nPHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\n23\n\n<<<PAGE 24>>>\n\nWHERE IS THE TRAINING PROVIDED?\nIt is important to evaluate the benefits of training programs as they relate to your company’s needs. Below is an example\nof a checklist and criteria that can assist you with this evaluation. Rows have been left blank so you can include additional\ncriteria that are important to your company.\nTRAINING LOCATION CHECKLIST IMPORTANT NEUTRAL UNIMPORTANT\nCommercially available programs off-site\n•\n•\n•\n•\nKnowledge/reputation of instructor Reputation of training organization Location of training Length of time employee will be absent from job □ □ □\n□ □ □\n□ □ □\n□ □ □\nCommercially available programs for in-house training\n•\n•\n•\n•\nKnowledge/reputation of instructor Reputation of training organization No interruptions while employees are in training Length of time required to complete program □ □ □\n□ □ □\n□ □ □\n□ □ □\nCompany-provided in-house instruction\n•\n•\n•\n•\n•\nAvailability of knowledgeable instructor No travel costs Lengt","truncated":true,"body_characters":51332}