DOT Training Requirements

hazmat, driver, drug and alcohol

By Michael Dodd

Training, you hear the word mentioned a lot, sometimes so much that you tend to forget the type and frequency of the required training. This article touches on the high points of the main training topics required by the DOT: hazmat, driver, drug and alcohol training.

Hazmat Training
The purpose of the training requirements in these regulations is to ensure that each hazmat employer trains its hazmat employees to recognize and identify hazardous materials as well as safely load, unload, handle, store and transport hazardous materials. The training is to ensure that the employee has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures.

A hazmat employer must train, test and certify every hazmat employee who, in the course of employment, has any function that directly affects hazardous materials transportation safety.

Hazmat employee (171.8) means a person who is employed by a hazmat employer and who, in the course of employment, directly affects hazardous materials transportation safety. This term includes an owner-operator of a motor vehicle which transports hazardous materials in commerce. This term includes an individual, including a self-employed individual, employed by a hazmat employer who, during the course of employment:

1. Loads, unloads or handles hazardous materials;
2. Tests, reconditions, repairs, modifies, marks or otherwise represents containers, drums or packagings as qualified for use in the transportation of hazardous materials;
3. Prepares hazardous materials for transportation;
4. Is responsible for safety of transporting hazardous materials; or
5. Operates a vehicle used to transport hazardous materials.

Hazmat Training Requirements (172.700-.704)
General Awareness — Each hazmat employee shall be provided general awareness and familiarization training designed to provide familiarity with the requirements of this subchapter, and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standards of this subchapter.

Safety — Each hazmat employee shall receive safety training concerning emergency response information, measures to protect the employee from the hazards associated with hazardous materials to which they may be exposed in the work place, including specific measures the hazmat employer has implemented to protect employees from exposure; and methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials.

Function Specific — Each hazmat employee shall be provided function-specific training concerning requirements which are specifically applicable to the functions the employee performs. Some examples of function-specific training for our business would be the following:

• Cylinder Filling:
      – high pressure, cryogenic liquids, liquefied gases such as carbon dioxide, LPG
         products and acetylene
• Cylinder Requalification:
      – high pressure (hydrotest)
      – Low pressure (visual)
      – Acetylene.
• Driver (see Driver Training below).

Security Awareness — This training must include an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. A component covering how to recognize and respond to possible security threats must be included.

Security, In-Depth Training — In-depth security training must include company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and organizational security structure.

Training must be done by December 22, 2003 and then whenever you update your security plan.

Driver Training (177.816)
177.816 says that the driver must receive training on the safe operation of the motor vehicle that will be transporting hazardous materials. This section goes on to describe in detail the issues the driver must be trained on.

Please note: 177.816(c) states: “The driver training requirements may be satisfied by compliance with the current requirements for a Commercial Driver's License (CDL) with a tank vehicle or hazardous materials endorsement.”

GAWDA has a Driver Training Manual available that is an excellent resource for driver safety meetings. It is set up into six short training modules with each module having its own test. A final, overall test covers all the topics in the manual. Each of these modules would make an excellent driver safety meeting training session of a few minutes each. If a company did one module every two months, the complete manual would be covered in a year. Refresher training could start again at the beginning the following year.

Hazmat Record of Training (172.704(d))
A record of current training, inclusive of the preceding three years, must be created and retained by each hazmat employer for each hazmat employee for as long as that employee is employed by the employer as a hazmat employee and for 90 days thereafter.

The record must include:

• Hazmat employee's name
• Most recent training completion date of the hazmat employee's training
• Description, copy or the location of the training materials used to meet the training requirements
• Name and address of the person providing the training, and
• Certification that the hazmat employee has been trained and tested.

Drug and Alcohol
382.601 covers two important points: a written policy and distributing that policy to your drivers.

Drivers are not required to undergo formal training. However, the employer must provide a copy of the company written drug and alcohol policy to each driver. Written notice of the availability of these materials must be provided to union representatives. These materials must be distributed prior to the start of alcohol and drug testing. Each driver must sign a receipt that he or she has received a copy of the materials.

382.603 covers training for driver supervisors. Each employer shall ensure that all persons designated to supervise drivers receive at least 60 minutes of training on alcohol misuse and receive at least an additional 60 minutes of training on controlled substances use. The training will be used by the supervisors to determine whether reasonable suspicion exists to require a driver to undergo testing under 382.307 (reasonable suspicion testing). The training shall include the physical, behavioral, speech and performance indicators of probable alcohol misuse and use of controlled substances. Recurrent training for supervisory personnel is not required.

Training Frequency
The hazmat (general awareness, safety, function specific—which includes driver training—and security awareness) must be done at least every three years. The supervisor drug and alcohol awareness training is only a one-time training.