Safety Training Program Highlights

About DOT HAZMAT Security Awareness

On May 15, 1992 the Department of Transportation (DOT) published Hazardous Materials Regulations (HMR) which enhanced training requirements and established a new Subpart H Training in 49 CFR. Since then several revisions have been made in both the content and structure of these training requirements, the most recent of which addresses the "security" of transported materials.

The purpose of these regulations is to make sure that employees who handle or transport hazardous materials:

• Are familiar with the general provisions of DOT's regulations on handling and transporting hazardous materials.


• Are able to recognize and identify hazardous materials.


• Know how the regulations relate to specific functions they perform.


• Are aware of "self protection" measures they should take when working with hazardous materials.


• Are aware of accident prevention methods and procedures to be used when working with hazardous materials.


• Know what should be done in an emergency involving hazardous materials.


• Are aware of the security risks associated with transporting hazardous materials.


• Know what can be done to enhance the security of transported hazardous materials.


• Be familiar with their employer's Security Plan.

These regulations are located in the Hazardous Materials Regulations in 49 CFR parts 100-185.

There are two definitions that are essential to understanding the training regulation and how it applies to any facility's activities.

These definitions deal with companies/facilities who are involved in handling and transporting hazardous materials... as well as the employees of these companies/facilities and how they are involved with hazardous materials:

• HAZMAT Employer - means a person (facility, company, institution, etc.) who uses one or more of their employees in connection with any of the following activities:


• Transporting hazardous materials in commerce.


• Causing hazardous materials to be transported or shipped in commerce.


• Being involved with any aspect of the packaging materials that are used in the transport of hazardous materials (such as producing, reconditioning or testing these packaging materials).

This definition includes owners/operators of motor vehicles which transport hazardous materials.

It also encompasses Federal and state departments and agencies.

• HAZMAT Employee - means a person who works for a HAZMAT Employer and who directly affects hazardous materials transportation safety.
  
  Activities that the DOT feels fit this definition include:


• Loading, unloading or handling hazardous materials.


• Working with hazardous materials' containers including testing, reconditioning, marking, etc.


• Preparing hazardous materials for transport.


• Having the responsibility for the safety of hazardous materials transportation.


• Operating a vehicle used to transport hazardous materials.

This includes self-employed individuals who are involved in these activities as well as owners/operators of motor vehicles used to transport hazardous materials.

It is easy to see that because these definitions are so broad, in many facilities and operations the regulations will cover many types of employees... from warehouse personnel to shipping/receiving groups, loading dock workers, truck drivers, train engineers, and others.

It is also important to recognize that this regulation applies to any environment where these activities take place.

This is not a regulation that is limited to "industrial" facilities, but includes laboratories, healthcare facilities and many other types of operations.

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DOT HAZMAT Security Awareness