The regulations of the PHMSA/USDOT at 49 CFR 172, Subpart H require a HazMat Employer to identify and train all of their HazMat Employees initially (within 90 days of hire) and at least once every three years thereafter. Training content must meet the requirements of 49 CFR 172.704. This presentation is a slightly updated and revised version of one I uploaded in 2012. It's purpose is to assist you in determining if you are a HazMat Employer (you are), if you employ any HazMat Employees (you do), and what training the regulations require.

1. THE IDENTIFICATION AND
TRAINING OF HAZMAT
EMPLOYEES
Pursuant to the regulations of the Pipeline
and Hazardous Materials Safety
Administration (PHMSA) of the USDOT
Identification & Training of HazMat Employees @DanielsTraining 1

2. PRESENTED TO:
Identification & Training of HazMat Employees @DanielsTraining 2
The 2013
Michigan
Safety
Conference
Thanks for the
opportunity!

3. PRESENTED BY:
Identification & Training of HazMat Employees @DanielsTraining 3
Daniels Training Services
815.821.1550
www.DanielsTraining.com
Info@DanielsTraining.com
A different kind of training.

4. A Question Before We Start…
•Have you
identified,
trained, and
tested all the
HazMat
Employees at
your facility?
Identification & Training of HazMat Employees @DanielsTraining 4
Leading source of
USDOT violations/fines

5. WHAT IS A HAZARDOUS
MATERIAL (HAZMAT)?
It all begins with the PHMSA/USDOT’s
definition of a hazardous material.
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6. What is a Hazardous Material?
• Defined @ 49 CFR
171.8, as capable of
posing an
unreasonable risk to
health, safety, and
property when
transported in
commerce.
Identification & Training of HazMat Employees @DanielsTraining 6

7. Hazardous Materials Include:
• Technical Name listed in Hazardous Materials
Table (49 CFR 172.101).
• Exhibits the characteristic of a hazard class or
division (49 CFR 173.2).
• Hazardous Substance (49 CFR 171.8).
• Hazardous Waste (49 CFR 171.3).
• Marine Pollutant (49 CFR 171.4).
• Elevated Temperature Material (49 CFR 171.8).
@DanielsTraining 7Identification & Training of HazMat Employees

8. Hazardous Materials are Common
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From LQG
or SQG

9. WHO OR WHAT IS A HAZMAT
EMPLOYER?
If you meet the definition of a HazMat Employer at
49 CFR 171.8, then you are responsible for
identifying and training your HazMat Employees.
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10. You are a HazMat Employer if…(1.0)
• You employ at least
one HazMat
Employee.
and…
1. Transport a
hazardous material
in commerce.
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Or….

11. You are a HazMat Employer if…(2.0)
• You employ at least
one HazMat
Employee,
and…
2. Cause a hazardous
material to be
transported in
commerce.
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Or….

12. Packaging Manufacturers are Also
HazMat Employers (3.0)
3. Design,
manufacture,
fabricate, inspect,
mark, maintain,
recondition, repair or
test a hazardous
material package or
package component.
Identification & Training of HazMat Employees @DanielsTraining 12

13. A HazMat Employer Includes
• Any department, agency, or instrumentality of the
US.
• A state or political subdivision of a state.
• An Indian tribe.
• An owner/operator of a motor vehicle.
Identification & Training of HazMat Employees @DanielsTraining 13
If they offer a HazMat
for transportation or
transport in commerce

14. WHAT IS A HAZMAT EMPLOYEE?
Which of your employees are HazMat
Employees?
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15. Defined at 49 CFR 171.8
Hazmat employee means: (1) A person who is:
(i) Employed on a full-time, part time, or temporary basis by a hazmat employer and who
in the course of such full time, part time or temporary employment directly affects
hazardous materials transportation safety;
(ii) Self-employed (including an owner-operator of a motor vehicle, vessel, or aircraft)
transporting hazardous materials in commerce who in the course of such self-
employment directly affects hazardous materials transportation safety;
(iii) A railroad signalman; or
(iv) A railroad maintenance-of-way employee.
(2) This term includes an individual, employed on a full time, part time, or temporary
basis by a hazmat employer, or who is self-employed, who during the course of
employment:
(i) Loads, unloads, or handles hazardous materials;
(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs,
or tests a package, container or packaging component that is represented, marked,
certified, or sold as qualified for use in transporting hazardous material in commerce.
(iii) Prepares hazardous materials for transportation;
(iv) Is responsible for safety of transporting hazardous materials;
(v) Operates a vehicle used to transport hazardous materials.
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HUH?!?

16. A Breakdown of the Definition (1.0)
• Employed full-time, part-time, temporary, or self-
employed.
and…
• Whose job directly affects hazardous material
transportation safety.
• Also includes…
• Railroad signalman.
• Railroad maintenance-of-way employee.
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17. A Breakdown of the Definition (2.0)
• HazMat Employee also includes full-time, part-time,
temporary, or self-employed who…
• Loads, unloads, or handles hazardous materials;
• Involved in any phase of manufacture of HazMat
packaging.
• Prepares hazardous materials for transportation;
• Is responsible for safety of transporting hazardous
materials;
• Operates a vehicle used to transport hazardous
materials.
Identification & Training of HazMat Employees @DanielsTraining 17

18. WHAT DOES A HAZMAT
EMPLOYEE DO?
The regulatory definition is a start, but it also
helps to have a description – with pictures! – of
the job duties of a HazMat Employee.
Identification & Training of HazMat Employees @DanielsTraining 18

19. A HazMat Employee has
Pre-Transportation Responsibilities
• Determines the hazard
class of a hazardous
material.
• Selects a hazardous
material’s packaging.
• For imports, provides
the shipper with
information about the
regulations.
Identification & Training of HazMat Employees @DanielsTraining 19

20. A HazMat Employee
Fills & Closes HazMat
Packagings
• Fills or loads a
hazardous materials
packaging.
• Secures a closure on
a hazardous
materials packaging.
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21. A HazMat Employee
Prepares HazMat Packagings
• Marks & labels
package to indicate
that it contains a
hazardous material.
• Ensures a package is
in proper condition for
transportation.
Identification & Training of HazMat Employees @DanielsTraining 21
HazMat Labels
Markings

22. A HazMat Employee
Assists the Vehicle Driver
• Loads or unloads HazMat
for transportation.
• Secures & segregates a
HazMat package in a
vehicle.
• Selects, provides, or
affixes placards.
Identification & Training of HazMat Employees @DanielsTraining 22

23. A HazMat Employee
Loads or Unloads HazMat
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This includes the loading or
unloading of bulk quantities

24. A HazMat Employee Assists in
Transportation by Rail
• Places warning signs,
blocks wheels, and
sets brakes on tank
cars placed for loading
or unloading with
closures open.
Identification & Training of HazMat Employees @DanielsTraining 24

25. A HazMat Employee
Provides Oversight and Supervision
• Certifies a hazardous
material is ready for
transportation.
• Supervises HazMat
Employees.
• Is responsible for the
safe transportation of
hazardous materials.
Identification & Training of HazMat Employees @DanielsTraining 25

26. A HazMat Employee
Handles Shipping Papers
• Prepares a hazardous
materials shipping
paper.
• Provides and
maintains emergency
response information.
• Reviews a hazardous
materials shipping
paper to verify
compliance with the
regulations.
Identification & Training of HazMat Employees @DanielsTraining 26

27. Including a Uniform Hazardous
Waste Manifest
• Prepares a uniform
hazardous waste
manifest.
• Provides and
maintains emergency
response information.
• Reviews a uniform
hazardous waste
manifest to verify
compliance with the
regulations.
Identification & Training of HazMat Employees @DanielsTraining 27

28. A HazMat Employee
Manufactures, etc. Packages
• Designs,
manufactures,
fabricates, inspects,
marks, maintains,
reconditions, repairs or
tests a package or
package component.
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29. A HazMat Employee
Operates a Vehicle Used to Transport
a Hazardous Material
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30. HOW MUST I TRAIN MY HAZMAT
EMPLOYEES?
Once you’ve identified your HazMat Employees,
you as the HazMat Employer must ensure they
are trained and tested per the requirements of
49 CFR 172, Subpart H.
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31. Training Requirements of
49 CFR 172, Subpart H
General Awareness/Familiarization
Function-Specific Responsibilities
Safety & Emergency Response
Security General Awareness
In-Depth Security
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32. Training Requirements of
49 CFR 177.816
Professional Driving Skills
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33. • Familiarity with the
general requirements
of the HMR.
• Enable a HazMat
Employee to recognize
and identify hazardous
materials.
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General Awareness/Familiarization

34. • A detailed
understanding of the
specific job function(s)
of the HazMat
Employee.
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35. • The hazards
presented by
hazardous materials.
• Safe handling.
• Emergency response.
• How to avoid
accidents.
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36. • Security risks
associated with
HazMat transportation.
• Methods to enhance
security.
• How to recognize and
respond to possible
security threats.
Identification & Training of HazMat Employees @DanielsTraining 36

37. • Applicability
determined by type
and amount of
hazardous materials
shipped.
• Refer to 49 CFR
172.800(b).
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38. • Company security objectives.
• Specific security procedures.
• Employee responsibilities.
• Organizational security structure.
and…
• Actions to take in the event of a security breach.
Identification & Training of HazMat Employees @DanielsTraining 38
Will also require the
HazMat Security Plan

39. When Train and How Often?
Initial
• Within 90 days of
employment or new
job assignment.
• Supervised by trained
and knowledgeable
personnel in that time.
Recurrent
• Full training at least
once every 3 years.
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40. Training Requirements
• HazMat Employee
must be tested as
part of training.
• HazMat Employer
ensures training and
testing is adequate
and appropriate.
• No training or
experience
requirement for trainer.
Identification & Training of HazMat Employees @DanielsTraining 40

41. HazMat Training Documentation
• Specific requirements
at 49 CFR 172.704(d).
• Retain training record
for current employees
until facility closure.
• At least 90 days from
HazMat Employee’s
last day.
Identification & Training of HazMat Employees @DanielsTraining 41

42. For More Information
1. What You Should
Know: A Guide To
Developing A
Hazardous Materials
Training Program
2. Does Your HazMat
Training Measure Up?
3. US DOT website:
HazMat Employee
Training
Requirements.
Identification & Training of HazMat Employees @DanielsTraining 42

43. I provide:
Annual RCRA
Training for
Hazardous
Waste
Personnel.
And
Triennial
HazMat
Employee
Training.
Public
Seminars,
Onsite,
Webinars…
ID & Management of Universal Waste in Michigan @DanielsTraining 43
Daniels Training Services
815.821.1550
Info@DanielsTraining.com
www.DanielsTraining.com
Got
Questions?