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All persons that work in the Dangerous Goods/Hazardous
Materials transportation field
must be trained. Training requirements are based on the mode of transport (air, ocean,
highway, rail) used and the job function performed.
|
Mode |
49 CFR
(USA Domestic) |
ICAO/IATA
(International Air) |
IMDG
(International Ocean) |
| Air |
X |
X |
. |
| Ocean |
X |
. |
X |
| Highway |
X |
. |
. |
| Rail |
X |
. |
. |
No matter which mode of transport used,
the employer/employee must adhere to the training requirements under 49 CFR, Subpart H. For all modes, all job functions, the following
apply:
- It is the employer's responsibility to
ensure their employees receive training.
- The employee may not perform their duties
unless they have received training.
- The employer may provide training or use an
outside source.
- The training must include a test.
Employees Must Be Trained in
the Following Areas:
- General Awareness training: provides
familiarity with the requirements and allows employees to recognize hazardous materials
(dangerous goods) in their workplace.
- Function-specific training: detailed
job-specific training. Example; if you mark and label packages, your training must include
detailed information on those subjects.
- Safety training: includes emergency
response and measures to be taken in case of an emergency at your workplace. This training
should also include proper handling procedures to avoid mishaps.
Other Requirements:
- The employee must be trained within 90 days
of hire or a change in job function(s).
- Until trained, the employee may perform
their job only under the direct supervision of a properly trained and knowledgeable hazmat employee.
- Relevant training received from a previous
employer or other source will satisfy the requirements as long as you have training
records from the previous employer.
- Employee records must be kept and include
the following:
- Employee's name.
- Date of most recent completed training.
- A description, copy, or the location of the
training materials used.
- Name and address of who provided the
training.
- Certification that the employee has been
trained and tested.
Retention of Records:
Records of current training, as well as the
preceding three years, must be maintained for each employee. If the employee leaves, the
records must be kept for an additional 90 days. The training records must be made
available upon request of the appropriate authority.
In addition to the above requirements
under 49 CFR, if you transport by air or ocean, there are
additional regulations you must comply with. For air transport on an IATA carrier, you must be certified to use the ICAO/IATA Dangerous Goods Regulations. For ocean shipments you must be trained according
to the IMDG regulations. The training requirements are almost
identical with the exception of recurrent training
frequency.
Training Curriculum
Table 1.5.A in the IATA Dangerous Goods
Regulations is based on ICAO Table 6-1, Content of Training Courses. It may be used as a
guideline applicable to most modes.
TABLE 1.5.A
Minimum Requirements for Training
Curricula (1.5.2)
Aspects of transport of
dangerous goods by air with which they should be familiar,
as a minimum |
Category of
Personnel See key below |
| . |
1 |
2 |
3 |
4 |
5 |
6 |
7 |
8 |
| General philosophy |
X |
X |
X |
X |
X |
X |
X |
X |
| Limitations |
X |
. |
X |
. |
X |
X |
X |
X |
| General requirements for shippers |
X |
. |
X |
. |
. |
X |
. |
. |
| Classification |
X |
X |
X |
. |
. |
X |
. |
. |
| List of dangerous goods |
X |
X |
X |
. |
. |
X |
X |
. |
| General packing requirements |
X |
X |
X |
. |
. |
X |
. |
. |
| Packing instructions |
X |
X |
X |
. |
. |
X |
. |
. |
| Labeling and marking |
X |
X |
X |
X |
X |
X |
X |
X |
| Shipper's Declaration and other relevant
documentation |
X |
. |
X |
. |
. |
X |
. |
. |
| Acceptance procedures |
. |
. |
X |
. |
. |
. |
. |
. |
| Storage and loading procedures |
. |
. |
X |
X |
. |
. |
X |
. |
| Pilots' notification |
. |
. |
X |
X |
. |
. |
X |
. |
| Provisions for passengers and crew |
. |
. |
|
X |
X |
. |
X |
X |
| Emergency procedures |
. |
. |
X |
X |
. |
. |
X |
X |
| Key: |
1 - |
Shippers and shipper's agents |
|
2 - |
Packers |
|
3 - |
Cargo acceptance staff of operators and
agencies acting on behalf of operators |
|
4 - |
Staff of operators and agencies acting on
behalf of operators engaged in the ground handling, storage and loading of cargo and
baggage |
|
5 - |
Passenger handling staff and security
staff who deal with the screening of passengers and their baggage |
|
6 - |
Staff of agencies other than operators
involved in processing cargo |
|
7 - |
Flight crew members |
|
8 - |
Crew members (other than flight crew) |
|
Note: |
Depending on the responsibilities of
the person, the aspects of training to be covered may vary from those shown in Table 1.5.A
-- e.g. if may be more appropriate for a packer to cover the aspects with which a shipper
should be familiar; if an operator carries only cargo, those aspects relating to
passengers may be omitted from the training programme for his staff and flight crew. |
Training Frequency
Once initial
training has been completed, you must receive recurrent
training to remain up-to-date on any changes to the regulations. The frequency depends on
the mode or job. However, in addition to the chart indicating training frequencies,
current US Department of Transportation regulations also state that "...training is
required every time changes in the regulations occur." This pertains only to the
hazardous materials you transport or your job function. *The IMDG
Code
does not reference a time frame therefore the 3-year recurrent period stated in
49 CFR, Subpart H, applies.
Recurrent Training
Schedule
|
Mode |
12
Months |
24
Months |
3 Years |
| Air |
. |
X |
. |
| Airline Employees (within the USA
only) |
X |
. |
. |
| Highway |
. |
. |
X |
| Rail |
. |
. |
X |
| *Ocean |
. |
. |
X |
References
IATA -
International Air Transport Association Regulations,
ICAO - International Civil Aviation Organization
49 CFR -
The 49th Code of Federal Regulations -
IMDG - International Maritime Dangerous Goods Code.
14 CFR -
Code of Federal Regulations, Subpart A, Part 121.433a and 135.333.
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