Editor’s Note: This column can serve as a companion article for the Consultant’s Roundtable on page 14.
Over the years, I have written several articles and Traffic Bulletins about training and with good reason. It consistently ranks as the number one inquiry from members and continues to be one of the most cited issues by DOT inspectors who visit our members.
I want to touch on the high points of the main training topics required by the DOT: function specific, HAZMAT, driver, and drug and alcohol training.
Hazmat Training (172.704)
A HAZMAT employer must train, test and certify every HAZMAT employee who has any function that directly impacts hazardous materials transportation safety.
Function-Specific Training Requirements (172.704)
Each HAZMAT employee shall be provided function-specific training concerning requirements which are applicable to the functions the employee performs. Some examples of function specific training for our GAWDA members include:
- Cylinder filling
- Cylinder requalification
- Special permits (This one has been a hot button for the past year or so. You must have trained and documented all employees affected by any cylinder special permit that you use or handle.)
Security Awareness (172.704)
This training must include an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. A component covering how to recognize and respond to possible security threats must be included.
Security, in-depth training (172.704)
In-depth security training must include company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach and organizational security structure. Be sure to cover all five components listed in 172.704 in-depth training.
Driver Training (177.816)
177.816 says that the driver must receive training on the safe operation of the motor vehicle that will be transporting hazardous materials.
Please note: 177.816 (c) states: The driver training requirements may be satisfied by compliance with the current requirements for a Commercial Driver’s License (CDL) with a tank vehicle or hazardous materials endorsement.
Hazmat Record of Training (172.704(d))
A record of current training, inclusive of the preceding three years, must be created and retained by each HAZMAT employer for each HAZMAT employee for as long as that employee is employed by the employer as a HAZMAT employee and for 90 days thereafter.
The record must include:
- Hazmat employee’s name
- Most recent training completion date of the HAZMAT employee’s training
- Description, copy or the location of the training materials used to meet the training requirements
- Name and address of the person providing the training
- Certification that the HAZMAT employee has been trained and tested
Reasonable Suspicion Training for Driver Supervisors
382.603 covers training for driver supervisors. Each employer shall ensure that all persons designated to supervise drivers receive training on alcohol misuse and controlled substances use. The training will be used by the supervisors to determine whether reasonable suspicion exists to require a driver to undergo testing under §382.307 (reasonable suspicion testing). The training shall include the physical, behavioral, speech and performance indicators of probable alcohol misuse and use of controlled substances.
The HAZMAT (general awareness, safety, function specific – which includes driver training – and security awareness) must be done at least every three years.
The supervisor drug and alcohol awareness training is only a one-time training, but I highly recommend reviewing this with driver supervisors every two to three years.