5 Hazardous Materials Training Recordkeeping Tips
Hazardous materials shippers often say that managing hazardous materials training is a challenge. Keeping track of employees’ training requirements, determining which transportation regulations to train for, ensuring the required training frequency, tracking regulatory changes and scheduling the training around a production schedule can certainly be a challenge. And these aren't all of the challenges; they must also consider recordkeeping.
The Hazardous Materials Regulations (HMR) requires that each hazmat employer create and retain a record of training for each hazmat employee for the preceding 3 years and for 90 days after the employee leaves their employment.
The training records must include: (See 49 CFR HMR §172.704(d))
- The hazmat employee's name
- The most recent training completion date
- A description, copy, or the location of the training materials used
- The name and address of the person providing the training
- Certification that the hazmat employee has been trained and tested
It is helpful to read the HMR’s introduction to training where it defines training as a systematic program that ensures hazmat employees are familiar with the compliance requirements for their specific tasks. If all you can provide to an inspector are some sign-in sheets from your training classes, you may fall short of the systematic program inspectors are looking to verify.
Here are 5 recordkeeping tips to document a systematic program of hazardous materials training.
1. Training Records: Use a sign-in sheet to capture training elements 1-4 listed above. You should also indicate that a test was administered, but there is no requirement to list employee test scores. You may want to also consider adding the following to the sign-in sheet:
- A reference to PHMSA publications used during the training. PHMSA has developed some excellent teaching aids that are available for free or at minimal cost.
- The name and signature of the employee supervising the training should there be any questions from the inspector about the training class.
Don’t forget that training is required each time the regulations change, no matter how minor the change may be. Hazmat employers must ensure that these changes are taught and recorded prior to the effective date of the regulatory change.
2. Employee Training Certificate: PHMSA expects to see a certification from the hazmat employer that each hazmat employee has been trained and tested in each of the required topics. In Letter of Interpretation 07-0015, PHMSA indicated that a general manager, shipping manager or personnel manager could sign the certificate. Each new training topic that is taught should be added to the employees’ training certificate with a certification.
3. List of Hazmat Functions: To support the recordkeeping requirements listed above, it’s wise to prepare a list of hazmat functions that are performed. Without a list of hazmat functions, it is difficult to know who and what training must be taught. A good way to start gathering the hazmat functions is to look at employee job descriptions and identify the hazmat functions listed. Also see 49 CFR HMR §171.1 for a list of hazmat functions.
4. Training Matrix: To demonstrate a systematic program of training, prepare a training matrix or training spreadsheet. Prepare the matrix by listing all employee positions (e.g., shipping clerk, cargo tank loader, etc.) across the top of the matrix (the columns) and all regulated hazmat functions (by mode of transport) down the side of the matrix (the rows). Place a check mark in the fields in the matrix where an employee position does a regulated hazmat function (e.g., at the intersection of: shipping clerk & certifies shipping papers). The matrix clearly indicates which employees perform each hazmat function, so it's evidence of a systematic program of hazardous materials training. (Also see Improving Your Hazardous Materials Training Experience)
5. Regulatory Monitoring: Without an effective regulatory monitoring program, it is difficult to know when the regulations are scheduled to change and when additional training is required. To demonstrate a systematic program of regulatory monitoring, create a calendar to show a regular review of the Federal Register, the official daily publication for rules, proposed rules and Federal notices. Another option is to purchase a service that will send you relevant Federal Register updates such as CyberRegs®.
With an emphasis on recordkeeping requirements, hazmat employers can quickly demonstrate their systematic program of hazardous materials training. This will pay dividends if your company undergoes an inspection and it will also improve your overall training program.
Comments: What recordkeeping tips for hazardous materials training have you implemented?