Improving Your Hazardous Materials Training Experience
Shippers of hazardous materials can provide hazardous materials training to achieve more than just regulatory compliance. Veteran employees typically have a good understanding of the compliance requirements, but PHMSA (Pipeline and Hazardous Materials Safety Administration) requires training at least once every 3 years. So why not take the opportunity to raise the bar on your hazardous materials training program by implementing these 5 hazardous materials training fundamentals?
Hazmat Training Fundamentals
1. Regulatory Scope: Transportation regulations are universally based on the UN Recommendations on the Transport of Dangerous Goods - Model Regulations. Why not take the opportunity to integrate the requirements from all transportation regulations that are applicable to your hazmat operations into your training plan, rather than teach each regulation separately? Regulatory scope is driven by the mode of transport (e.g., Air - Dangerous Goods Regulations, Ocean - IMDG Code, Road & Rail - Hazardous Materials Regulations, etc.). To improve compliance, take advantage of this content overlap between transportation regulations to illustrate the similarities and differences in regulated hazmat functions (e.g., preparing hazmat drums for shipment).
Fundamental 1: Identify all modes of transportation used to ship hazmat.
2. Job Descriptions: To ensure hazmat employees receive the appropriate hazardous materials training requires that each employee has a job description that lists their responsibilities. Expecting employees to jump into any task that needs doing could place them out of compliance and possibly lead to unsafe work conditions, so it’s important to identify the job responsibilities of each hazmat employee or position.
Fundamental 2: Develop detailed job descriptions for employees.
3. Training Content: Transportation regulations require that hazmat employees are provided with several types of training. This training includes:
- General awareness
- Function specific
- Security awareness and
- In-depth security training
General awareness training is an overview of all the regulatory requirements. Knowing the regulatory scope of your operations (Fundamental 1) allows you to develop a single general awareness/security awareness training program for your company that encompasses the applicable regulations. To develop the content for function specific, safety and in-depth security training, you need to review the responsibilities listed in your job descriptions (Fundamental 2) to identify the regulated responsibilities. Each regulated responsibility will typically involve several hazmat functions. For example, the responsibility to prepare hazmat drums for shipment may include:
- Selecting packagings
- Filling packagings
- Closing packages
- Labeling packages
- Marking packages
Fundamental 3: Develop a general awareness/security awareness training program and a list of hazmat functions based on the responsibilities listed in your company's job descriptions.
4. Training Matrix: To organize the information developed in Fundamentals 1-3, create 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 general awareness/security awareness training developed in Fundamental 3 will be applicable to all hazmat employees. A matrix will ensure the training is comprehensive, tailored and relevant to each employee. The matrix will also be your road map for future training. When regulations change, it will be easy to determine which employees need recurrent training.
Fundamental 4: Create a training matrix based on Fundamentals 1-3.
5. Training Courses: If you group the training of hazmat functions by how they are performed in the workplace (e.g., teach selecting, filling, closing, labeling and marking of hazmat drums as one unit), the training course (e.g., Preparing Hazmat Drums for Shipment) becomes a step by step process on how to do the task. This will improve understanding by employees. To further enhance the training, incorporate the operational steps and regulatory requirements into a checklist. (See The Benefits of Using Logistics Safety Checklists)
Fundamental 5: Group your training modules and present them as work procedures.
With some planning, you can systematically improve your hazardous materials training and make it more relevant to your employees. This will improve employee knowledge and understanding of the compliance requirements and raise the bar on your logistics safety performance.