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Employees Preparing Hazardous Waste Materials For Shipment

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Most employers know their business well. They know their competitors, know how best to build their products and they know how to successfully get their product to the customer. What most employers DON’T know is that if they have employees who prepare hazardous materials for shipment or who transport hazmat in commerce as part of their job, there are stringent requirements and responsibilities placed on them as hazmat employers.

The Hazardous Materials Regulation (HMR) defines a hazmat employee as a person employed full-time, part-time, temporarily or self-employed who is directly affecting hazmat transportation safety by loading, unloading or handling hazardous material, is a railroad signalman or maintenance-of-the-way employee, or who designs, manufactures, inspects, marks, tests or reconditions containers, or who prepares hazmat for transportation or operates a hazmat transport vehicle. It requires hazmat employers to provide certain training to these employees … and there are stiff penalties for not complying!

The intent of the HMR is to ensure that hazmat employees are familiar with HMR, are trained and able to recognize/identify hazardous materials, are able to understand the dangers and consequences of their job, are knowledgeable about emergency response, self-protection measures, security awareness and accident prevention.

At a minimum, HMR requires that an employer:

  • Provide training to meet DOT 49CFR 172.704. Training may be conducted by the employer or a private or public trainer within 90 days of hazmat employment. Training required by OSHA 29 CFR 1910.210 or 1910.1200 and EPA 49CFR 311.11 may be used if it also addresses the issues in 49CFR 172.704
  • Test the employee on their training
  • Certify that the employee was trained/tested
  • Keep records of such training/testing
  • Provide recurrent training every (3) years for DOT or when revised and annually for OSHA and EPA

If you have questions regarding who in your employ might qualify for this training or you have questions regarding the training, call Safeway Industrial and let our experience and training work for you!

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