You know how the old adage goes: “Train as if your life depends on it, because it does.” This is especially true when it comes to hazardous materials training – many lives depend on the proper training of Hazmat Employees.
As we have mentioned before, if you have hazardous chemicals in your facility (and remember that acetone and gasoline are hazardous chemicals), you must comply with DOT hazmat rules (Title 49 CFR 172, Subpart H) and OSHA’s Hazard Communication (“Right to Know”) Standard. If you don’t regularly ship hazmat or you are not a manufacturer of hazardous materials, don’t think that your dealership is immune to the regulations. Whether you or ship hazardous materials once per year or every day; around the block or across the country; in a small package or in a tank: You must protect your employees and the public from any potentially adverse effects of the chemicals being handled.
The idea is pretty straightforward: Workers have a right to know about the substances and chemicals with which they come in to contact, and any risks they may be exposed to, as well as the proper protective equipment to use. Under the Hazard Communication Standard, shippers are also required to maintain a database of Material Data Safety Sheets (MSDS) and a facility-specific chemical inventory of the chemical products stored and used throughout their facility.
Every employee who affects the safety of hazardous materials transportation is a Hazmat Employee and must be trained. This definition also applies to the owner or the operator of the vehicle transporting the hazardous materials in commerce or any employee who, during his or her course of employment:
- Handles, loads, or unloads hazardous materials
- Manufactures, marks, classifies, labels, packages, or otherwise represents containers, drums, or packagings which are classified for use in the transportation of hazardous materials
- Prepares hazardous materials for transportation
- Is responsible for storage and disposal of hazardous materials
- Is responsible for safety of transporting hazardous materials
- Operates or owns a vehicle to transport hazardous materials
Take this simple quiz to see if your dealership could pass an OSHA/DOT audit:
- Do you have records confirming at least one employee has DOT Hazmat Certification?
- Is this training being updated every three years?
- Did this training include the newly required “Security Awareness” training?
- Are you following the proper procedures for hazardous shipments using the proper labels, classifications, identification numbers, and packing groups according to the DOT’s hazardous materials table?
- Do you provide the required 24-hour emergency contact phone number on your shipping papers?
Read more of our EHS DOT blogs.