HAZMAT TRAINING

The Research and Special Programs Administration of the DOT, (RSPA), created Part 180, "The Continuing Qualification and Maintenance of Packaging" because investigations of tank truck operations revealed that, prior to 1985, many cargo tanks were not well maintained (particularly components like vents, manholes and emergency valves). There was also evidence that cargo tank vessels were poorly maintained, and repairs were often of poor quality. Incidentally, DOT's use of the word "packaging", in our case, is RSPA terminology for cargo tanks.

The use of the term "Continuing Qualifications" stems from the concept that when a cargo tank is manufactured it is "Qualified" as a hazardous materials package by the manufacturer. After varying periods of time, depending on the type tank, it must be inspected and maintained or it will no longer be "qualified".

Part 180 lays the ground rules for those inspections and required maintenance procedures necessary for a HM cargo tank to continue to be qualified and to be used in hazardous material transportation.  They may continue in service for as long as they are able to meet part 180 requirements.  This section of the Maintenance Manual is an explanation of those requirements in general. The individual sections covering Specification DOT-406/MC-306, DOT-407/MC-307, DOT-412/MC-312, MC 330/331, will explain in detail the requirements for each type. There may be some duplication. Additionally, recommendations are included for certain non-specification tanks.

The U.S. Department of Transportation (D.O.T.) requires that a thorough inspection be given to all commercial vehicles using the nations rail, highway, and waterways systems. All such inspections must be completed by qualified individuals and properly documented before any vehicle can be loaded or shipped.

The scope of these inspections for Cargo Tanks are covered under 49 CFR, parts: 172, 173, 177, 180, 396, and 397 (D.O.T). In addition to those applicable parts of the Process Safety Management Regulations 29 CFR 1910.119 (OSHA).

Following these regulations will assure the tank, tank fittings, safety appliances, running gear, underframe, stenciling and required testing are in good working order and up-to-date. The individuals ability to perform these inspections thoroughly and efficiently depends on the quality of their training and experience doing the job.
 

Training Requirements......It's the Law!

Code of Federal Regulations
 Title 49, Subpart H, §172.700-172.704
(Formerly Docket HM-126F)

 

PHMSA amended the Hazardous Materials Regulations (HMR) in conformance with amendments to the Federal Hazardous Materials Transportation Law that required DOT to regulate the training of all hazardous materials (hazmat) employees. Training which meets these requirements will increase a hazmat employee's safety awareness and be an essential element in reducing hazmat incidents.

 

Training and the Hazmat Law

The Federal hazardous materials transportation law (49 U.S.C. § 5101 et seq.), is the basic statute regulating the transportation of hazardous materials (hazmat) in the United States. This law requires the training of ALL hazmat employees. The purpose is to increase a hazmat employee's safety awareness and be an essential element in reducing hazmat incidents. The Hazardous Materials regulations (HMR) include training requirements in several sections of Title 49 Code of Federal Regulations (CFR) as follows:

 
Each Hazmat Employer Must:
  • Train and Test
  • Certify
  • Develop and retain records of current training (inclusive of preceding three years) for each hazmat employee (during the period of employment and 90 days thereafter)
Training Must Include:
  • General awareness/familiarization
  • Function-specific, training
  • Safety
  • Security awareness
  • In-depth security training, if a security plan is required
  • Driver training (for each hazmat employee who will operate a motor vehicle)

Initial Training:

 

A new employee, or an employee who changes job functions, may perform hazmat job functions before completing training, provided:

  • The employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee; and
  • The hazmat training is completed within 90 days of employment or change in job function.
Recurrent Training:
  • Is required at least once every three years. The three year period begins on the actual date of training.
  • Relevant training received from a previous employer or other source may be used to satisfy the requirements, provided a current record of training is obtained from the previous employer or source (i.e., OSHA, EPA, and other Federal or international agencies.) Training must address components specified in 172.704(a) of the HMR to be considered applicable.
Training Records Must Include:
  • Hazmat employee's name
  • Completion date of most recent training
  • Training Materials (Copy, description, or location)
  • Name and address of hazmat trainer
  • Certification that the hazmat employee has been trained and tested.

 

GENERAL § 173.1

SPECIFIC § 172.704

MODAL