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Is
Hazmat Training Critical to your Business?
By
Alan I. Roberts, Associate Administrator for Hazardous Materials
Safety
U.S. Department of Transportation, Research and Special Programs
Administration
Reprinted with permission from http://hazmat.dot.gov
More
than one-third of the Department of Transportation's Research
and Special Programs Administration's enforcement actions
pertaining to violations of the hazardous materials transportation
regulations involve the failure of hazmat employers to provide
training or maintain test records.
In
most cases violations are attributed to failure to provide
function specific training. For example, an investigator questions
incorrect entries on a shipping paper prepared by a hazmat
employee who responds that he was not instructed, nor tested,
by his hazmat employer regarding the preparation of shipping
documents.
Some
hazmat employers rely on persons who claim they provide training,
without checking their qualifications and references. We have
heard of so-called hazmat training entities who claim the
quickest (least time consuming) and lowest price training
programs that include tests and certificates of completion.
I suggest that when you see or hear of such a claim, you closely
check the credibility of their claims. We list on the DOT/RSPA
website a number of organizations and businesses who provide
hazmat training. Most are excellent sources of training, but
we cannot attest that all who avail themselves of the opportunity
to be listed are providing training that would result in compliance
with the hazmat training regulations.
One
question you should ask is whether the training provided of
the general awareness type, or function specific to the kind
of activities conducted by your company. In addition, you
should determine if the safety training is appropriate to
your business activity. For example, the safety training provided
a driver who unloads cargo tanks may be quite difference from
the safety training given transportation workers who handle
infectious medical wastes.I strongly recommend you consider
hazmat training as a critical element to the future of your
business and not as something that management, including senior
management will look into during an enforcement proceeding,
or after an accident. When training becomes an issue after
an accident, a DOT penalty action may not be most significant
when compared to the outcome of a civil proceeding to determine
the extent of liability or punitive damages.
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