HMR Training Requirements & Responsibilities

Here is an HMR information reminder for all of you that have Hazardous Material as part of your program. HMR Training Requirements and Responsibilities The Hazardous Material Regulations (HMRs; 49 CFR Parts 100 – 185) issued by the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) establish requirements for the safe transportation of hazmat by highway, rail, vessel, and air. The HMRs specify appropriate packaging and handling requirements for hazardous materials, and require a shipper to communicate the material’s hazards through the use of shipping papers, package marking and labeling, and vehicle placarding. The HMRs also require shippers to provide emergency response information applicable to the specific hazard or hazards of the material being transported. The HMRs mandate training requirements not only for persons who prepare hazmat for shipping, but also those who transport hazmat in commerce. The intent of the regulations is to ensure that each hazmat employee is familiar with the HMRs, is able to recognize and identify hazardous materials, understands the specific HMR requirements applicable to the function he/she performs, and is knowledgeable about emergency response, self-protection measures, and accident prevention methods. This is clearly stated in Subpart H - Training in Part 172 of the HMRs, and applies to hazmat employers and hazmat employees as defined in §171.8. Responsibility for training and compliance with the HMRs can be found in §177.800 and applies to all motor carriers of hazardous materials, including private, common, and contract carriers. Training requirements specific to the actual operation of the motor vehicle by the driver are listed in §177.816 - Driver Training, and are in addition to the training requirements stated in §177.800. Also, §172.704 - Training Requirements lists the different areas of training that are required:

• General awareness/familiarization training. Enables the hazmat employee to recognize and identify hazmat. All employees must receive general awareness training.

• Function-specific training. Each hazmat employee must be trained on the specific functions he/she is required to perform, such as loading or unloading a vehicle, making out shipping papers, etc.

• Safety training. Training that covers the hazards presented by hazardous materials, safe handling, emergency response information, and methods and procedures for accident avoidance. All hazmat employees must receive this training.

• Security awareness training. Training that provides a general understanding of the security risks associated with hazardous materials transportation and the methods designed to enhance transportation security. All training should include methods on how to recognize and respond to possible security threats. All employees must receive this training.

• In-depth security training. Training that provides a detailed understanding of a company’s security plan, including company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure. This training must be provided to hazmat employees who handle or perform regulated functions related to the transportation of the materials covered by the security plan and to those who are responsible for implementing the security plan.

Finally, The HMRs require all hazmat employees to be trained, as well as hazmat employers with direct supervision of hazmat transportation functions. Rack ‘em up Storing materials in warehouses can present some tall challenges for safety managers. For instance, improperly stacked materials can fall from heights, exposing workers to struck-by hazards. OSHA usually enforces racking safety under the General Duty Clause, and typically references the manufacturer’s instructions as well as industry consensus standards for racking design. However, the Agency may also cite a warehouse under the stacking safety requirement at 29 CFR 1910.176(b), which states that, “Storage of material shall not create a hazard. Bags, containers, bundles, etc., stored in tiers shall be stacked, blocked, interlocked, and limited in height so that they are stable and secure against sliding or collapse.” To store materials properly, OSHA recommends:

• Stacking loads evenly and straight;

• Placing heavier loads on lower or middle shelves;

• Removing one object at a time from shelves;

• Keeping aisles and passageways clear;

• Keeping shelves in good repair;

• Properly stacking, blocking, interlocking, or limiting the height of loose or unboxed materials in a pile to prevent falling hazards;

• Properly stacking, blocking, interlocking, or limiting the height of bags, containers, and other bundles so that they are stable and secure enough to prevent sliding or collapse.

More specifically, OSHA’s guidance on Materials Handling and Storage describes how to safely stack lumber and bricks, piping, baled paper and rags, and boxed materials. In addition, workers are instructed to do the following:

• Paint walls or posts with stripes to indicate maximum stacking heights for quick reference;

• Observe height limitations when stacking materials;

• Consider the need for availability of the material.

Update 5/12/2015