Are Your Employee‘s Subject To Haz-mat Training?

In a letter recently submitted to the US Department of Transportation (DOT), a packaging manufacturer asked if his employees were subject to Hazardous Materials training as specified in CFR49, Parts 171-180. The package, which they produce, is intended for the transport of hazardous materials. In response, DOT stated that yes, even though they do not manufacture a dangerous good, they are within the definition of a HazMat employee. As defined in CFR 178.8, a person employed in a company that directly affects hazardous materials is required to comply with HazMat training. This includes an individual who loads, unloads or handles hazardous materials; manufactures, sells, tests, reconditions, repairs, modifies, marks or represents containers, drums, or packagings as qualified for use in the transportation of hazardous materials; prepares hazardous materials for transportation; is responsible for safety or transporting hazardous materials; or operates a vehicle used to transport hazardous materials.
Non-compliance to this regulation is considered a violation of the CFR.