Avoiding DOT Function Specific Training Pitfalls
Function Specific Training Requirements
Department of Transportation (DOT) training is required in accordance with Subpart H of 49 CFR Part 172. Function Specific training is referenced specifically in § 172.704(a)(2)(i), which clearly states that anyone who performs a regulated function must be trained on the specifics of the Hazardous Materials Regulations, as it relates to their job function:
Each HazMat employee must be provided function-specific training concerning requirements of this subchapter, or exemptions or special permits issued under subchapter A of this chapter, that are specifically applicable to the functions the employee performs.
HazMat Employees – More People Than You Think
Employers need to be very careful about who is considered a “HazMat employee” because 49 CFR § 171.8 defines HazMat employee to include more roles than you think. This includes anyone, even temporary employees, handling HazMat (i.e., receiving department), transporting any quantity of HazMat (e.g., company van driver), or preparing HazMat for transportation (e.g., filling a cylinder or packing HazMat shipment). The section partially states:
(2) This term includes an individual employed on a full-time, part-time, or temporary basis by a HazMat employer or who is self-employed, who, during the course of employment:
(i) Loads, unloads, or handles hazardous materials;
(ii) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce.
(iii) Prepares hazardous materials for transportation;
(iv) Is responsible for the safety of transporting hazardous materials;
(v) Operates a vehicle used to transport hazardous materials.
In-House Training
It is impossible for a 3rd-party, off-the-shelf training program to fully comply with 49CFR requirements for Function Specific training for every business. The content must be tailored to each company and be specific to the obligations of each job function.
Therefore, most companies choose to perform Function Specific training in-house for obvious reasons: no one understands their business like they do.
To save time and money, consider low-cost, generic training available online that covers job functions for which this type of training is available, such as HazMat or Dangerous Goods shipping. Then, supplement with in-house training that covers additional specifics. Ensure that the trainer understands the requirements fully (including the contents of the course taken) and supplements training content based on the job function of the trainee. Be careful to document the training in accordance with § 172 Subpart H. It is unlikely that your existing training program can provide such documentation, so it will likely need to be customized accordingly. Also review the 3rd party training records to ensure they comply with the regulations.
Other job functions, such as filling cylinders or bulk containers, will likely not be available from a 3rd party. In this case, an in-house training curriculum will be required to be produced. If you do this alone, be sure to involve all relevant departments management such as quality, legal, and production. Technical information should be gleaned from your most experienced and knowledgeable employees and passed through a very fine compliance and legal “filter.” You may find it is more effective to outsource this process, above all, to avoid adding such a burden to key personnel.
Outsourcing is a Cost-Effective Option
Now that you understand the requirement and still likely choose to train in-house, ask a few questions: Does your organization have the expertise to develop appropriate training content and the resources to deliver it in a compliant way? Do management and experienced line personnel have the time to dedicate to a compliant training course? Are you sure you are considering all the requirements?
Tym’s will review your HazMat operations and create a compliant and effective DOT Function Specific training solution for your organization in a faction of the time and expense than doing so in-house.
If your company hasn’t fully complied with DOT Function Specific training requirements, we will supplement your current training program with a cost-effective solution that removes the burden from your team and ensures compliance.
Reach out today:
https://tymsllc.com/contact-us/