Personnel working with hazardous materials in the United States may be required to have specific training to meet both client and regulatory requirements. The agency enforcing the regulations can further break out the hazardous materials training requirements based on the associate's type of work.
The Pipeline and Hazardous Materials Safety Administration (PHMSA) enforces hazardous materials transportation operations with oversight by the Department of Transportation (DOT). The Occupational Safety and Health Administration (OSHA) under the Department of Labor (DOL) enforce general operations, emergency response, and waste clean-up operations. The Environmental Protection Agency (EPA) enforces hazardous waste management and disposal operations.
This discussion reviews each area and provides a breakdown of the training requirements, frequency and applicability.
Hazmat Transportation
Hazmat training is required for all personnel who can impact the safety of hazardous materials during their transport. All personnel responsible for the safe transport of hazardous materials must understand the hazmat transportation rules and regulations. Hazmat training is a requirement for personnel who perform any of the following tasks:
- Read and interpret regulations;
- Supervise hazmat shipping operations;
- Classify or name hazardous materials for transport;
- Package shipments or load trailers/containers;
- Place hazmat marks and labels on shipments;
- Load or unload vehicles;
- Prepare or sign hazmat shipping papers;
- Deliver packages; and
- Personnel who train crews to handle hazardous materials.
Hazmat training requirements include five specific topics to comply with DOT regulations found in 49 CFR 172.704:
- General hazmat awareness;
- Function-specific hazmat training;
- Hazmat security awareness;
- Hazmat safety training; and
- Hazmat security plan training (if applicable, based on materials shipped).
New personnel responsible for the safe transport of hazardous materials must be trained within 90 days of hire date. Until the training is complete, the new hire must work under supervision. Additionally, every associate responsible for the safe transport of hazardous material must repeat refresher training at least once every three years.
International Shipments- IATA and IMDG
In some cases, personnel may be required to perform tasks that affect the international transportation of hazardous materials. For example, the transportation of hazardous materials by air requires training in the International Air Transport Association (IATA) Dangerous Goods Regulations. Likewise, transportation by vessel requires training under the International Maritime Dangerous Goods (IMDG) Code. IATA training is required every two years, while IMDG training is required every three years.
General Hazmat Operations
General hazmat operations consist of two main areas under OSHA, HAZCOM and HAZWOPER.
OSHA Hazard Communication
Hazard communication (HAZCOM) training is required for all employees who work with or may be exposed to hazardous chemicals within their job function. This training teaches employees to recognize and use hazard labels and Safety Data Sheets to protect themselves and their co-workers from chemical hazards on the job. HAZCOM training is required within six (6) months of employment and required to be repeated annually. Regulatory requirements for HAZCOM can be found in 29 CFR 1910.1200.
OSHA HAZWOPER
HAZWOPER stands for "Hazardous Waste Operations and Emergency Response." HAZWOPER was put in place to protect personnel who perform emergency response or contaminated site clean-up involving hazardous substances, including EPA hazardous wastes, CERCLA hazardous substances, DOT hazardous materials, and biologic agents. HAZWOPER training requirements are complex, consisting of a minimum of 24 hours, as well as additional amounts and types of training for different levels of emergency responders, site clean-up workers, and workers at specific hazardous waste processing facilities.
Who Needs HAZWOPER Training?
Clean-up site workers, those who work at hazardous waste treatment, storage, and disposal facilities (TSDF), and emergency responders receive HAZWOPER training. While all three groups of personnel need 24-hour HAZWOPER training, the information covered during the 24 hours will vary based on an associate's specific responsibilities under the HAZWOPER Standard (see below). Each of the three main categories has its own set of training requirements.
- Clean-up site workers are workers directly involved in a hazardous substance or hazardous waste clean-up activity, for instance, people who work at "EPA Superfund "sites.
- TSDF workers are personnel who work at permitted hazardous waste facilities that treat, store, and dispose of hazardous waste. Personnel covered here would only include those workers involved with the TSDF operation.
- Emergency responders are employees who respond to emergencies involving hazardous substances. This includes people like firefighters but also facility employees who handle on-site emergency response for their employer. It is important to note that if an employee performs emergency response at clean-up sites or TSDFs, they will fall into the first two categories.
Emergency responders are broken out into five categories:
Level 1 - First responder "awareness level" – Employees who do not do any active response, only sound the alarm that something is wrong.
Level 2 - First responder "operations level"– Employees who will respond defensively to a release to protect nearby persons, property, or the environment. These employees would take measures to contain the spill from spreading further.
Level 3 - "HAZMAT technician"- Employees who will respond offensively and will aggressively try to stop the release. These employees would try to plug the leaking drum.
Level 4 - "HAZMAT specialist"- Employees who support technicians, including technical knowledge and guidance, and act as liaisons to government authorities.
Level 5 - "On-scene incident commander"- Employees who assume control of the incident scene beyond the first responder awareness level.
HAZWOPER refresher training must be completed annually and consists of eight hours of topics relevant to the associate's job function. Beyond the classroom training, employees may be required to complete additional hands-on/field training to meet the HAZWOPER requirements.
EPA- RCRA Hazardous Waste Training
Hazardous waste training is required for all "hazardous waste personnel" within six months of hire or assignment to the facility. US EPA defines "hazardous waste personnel" as all persons who work at, or oversee the operations of, a hazardous waste facility and whose actions or failure to act may result in noncompliance with the requirements (of the RCRA regulations)."
Typical responsibilities for hazardous waste personnel include:
- Identify or count hazardous waste;
- Choose hazardous waste containers;
- Mark or label containers;
- Handle or move waste or waste containers;
- Inspect containers;
- Operate a waste-generating process;
- Manage waste in satellite areas; and
- Read and apply Federal or state hazardous waste regulations.
Training requirements for RCRA Hazardous Waste are based on the category of the Generator. There are three (3) categories of RCRA Hazardous Waste Generators:
Large Quantity Generator (LQG) is a facility that generates more than 1000 kg (2,200 pounds) of hazardous waste or more than 1 kg (2.2 pounds) of acutely hazardous waste in a given month. Hazardous waste personnel at large quantity generator facilities must complete a program of annual RCRA refresher training (40 CFR 262.17(a)(7)). At a minimum, training "must be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems."
Small Quantity Generator (SQG) is a facility that generates less than 1000 kg (2,200 pounds) of hazardous waste and 1 kg or less of acutely hazardous waste per month. For small quantity generators (SQGs), US EPA requires that all hazardous waste personnel are "thoroughly familiar" with the RCRA regulations. To ensure personnel fully understand their responsibilities and have up-to-date training, annual training for SQG personnel is a best practice.
Very Small Quantity Generator (VSQG) is a facility that generates 100 kg or less of hazardous waste per month. There is no specific training required for VSQG personnel, however employees should be familiar enough with the requirements to manage hazardous waste in compliance with regulations safely.
As discussed above, hazardous materials training requirements can be difficult to navigate. It is recommended to reach out to a Safety professional for further clarification.
