Overview
The Department of Transportation (DOT) sets requirements for training hazmat employees. Training means a systematic program that ensures a hazmat employee has familiarity with the general requirements, is able to recognize and identify hazardous materials, has knowledge of specific requirements applicable to functions performed by the employee and has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures.
Security Awareness Training
Each hazmat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats. New hazmat employees must receive the security awareness training within 90 days after employment.
In-Depth Security Training
Each hazmat employee of facilities that are required to have a security plan who handles hazardous materials covered by the plan, performs a regulated function related to the hazardous materials covered by the plan or is responsible for implementing the plan, must be trained concerning the security plan and its implementation. Security training must include company security objectives, organizational security structure, specific security procedures, specific security duties and responsibilities for each employee and specific actions to be taken by each employee in the event of a security breach.
The company’s security plan is the primary training material of choice because the content of the training must include instruction or information on company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach and the organizational security structure. Use of third-party instruction materials may only augment material that is specific to your security plan. If your security plan accommodates varying threat levels, your in-depth training should inform employees of the policies, procedures and actions expected of them at each threat level.
For in-depth security training, a hazmat employee must be trained at least once every three years or, if the security plan for which training is required is revised during the three-year recurrent training cycle, within 90 days of implementation of the revised plan.
RecordKeeping
A record of current training, inclusive of the preceding three years, must be created and retained by each hazmat employer for as long as that employee is employed by that employer as a hazmat employee, and for 90 days thereafter. The record must include:
- The hazmat employee’s name;
- The most recent training completion date of the hazmat employee’s training;
- A description, copy or the location of the training materials used to meet the requirements;
- The name and address of the person providing the training; and
- Certification that the hazmat employee has been trained and tested