The U.S. Department of Transportation requires every hazmat employer to provide one or several types of training to hazmat employees that perform hazmat transportation functions. Industrial packaging manufacturers, reconditioners, distributors and shippers that cause packagings of hazardous materials to be shipped in transportation, are considered hazmat employers. A hazmat employee is a part-time or full-time employee whose job responsibility “…directly affects hazardous materials transportation.” There are several tiers of training that may apply to your business facilities. They are:

General awareness. This basic level of training applies to all covered employees and includes and is intended to familiarize employees with the basic requirements of the Hazardous Materials Regulations.

Function specific. This secondary training level applies to employees performing key job functions, such as applying markings to containers or operating the leakproofness tester.

Safety. All hazmat employees must receive safety training concerning how to respond to emergency situations; how to protect themselves from exposures to hazmat; and procedures for avoiding accidents. If you provide OSHA, EPA or other training on these subjects, you are not required to re-train employees.

Security awareness training. All employees should receive some basic plant security information, which is required as part of this training level. This training need not be extensive   as it might be for a chemical facility, for example   but be sure to inform your employees about security access points, etc.

In-depth security training. If your plant is required to develop and maintain a security plan, employees must be aware of the plan and its contents.
When must hazmat employee training take place? All new employees performing hazmat functions, and employees that change jobs in a company and become a hazmat employee, must be trained within 90 days. Even though the regulations state that during the initial 90-day period newly hired employees may work in the plant if they are directly supervised. However, hazmat employees are subject to training once they begin actively working.

Testing. DOT requires employers to maintain proof (“certification”) that every hazmat employee has been trained and tested. Be sure your training certificates are dated and signed by the employee and the person doing the training.

Record keeping. Training records must be maintained for each covered employee and be retained for as long as the employee works for the company, and 90 days thereafter.

Usage of steel drums continues to defy contenders as being the most reliable packaging for the shipment of dangerous goods. However, while the popularity is sustained, there are some manufacturers that are offering reduced metal thickness in order to offset steel price increases. The result is that while these thin gauge steel drums are able to marginally qualify for the minimal requirements of the DOT and UN certification, they do not perform as well in-field. Gone are the days of drum failures due to seam leaks — today’s most common incidents are related to fork-lift puncture and material handling. This change in the type of incidents, and the reduction of metal thickness leads one to conclude that these thin walled drums might be paving the way for a new set of in-transit incidents. Furthermore, shippers of steel drums fail to realize the g-forces associated with steel drum shipments and often ignore, or underestimate, adequate blocking and bracing preparation. CFR49 173.28(4)(i) states that for steel drums intended for reuse, 0.92mm is the minimum allowable steel gauge or a 0.82 body is allowed if the heads are 1.11mm. Even at these minimum levels, we recommend that thicker options are preferred because of the reduced risk of the transport package. Don’t risk the loss of your expensive contents in order to save a few cents a pound on the steel.