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COUNTERMEASURE
Objective: To improve hazardous materials transportation safety through the comprehensive training of Hazmat employees.
Description: A high percentage of hazardous materials incidents are caused by human error and lack of proper training. The number of such incidents may be greatly reduced by the thorough training of Hazmat employees.
Questions for Management:
1. What supervisory personnel are responsible for Hazmat shipments and are these people
properly trained?
2. Are all Hazmat employees trained to handle hazardous materials incidents?
3. Are Hazmat employees given emergency response training?
4. Are Hazmat employees aware of correct procedures for notifying authorities of an incident?
5. Can Hazmat employees properly use the Emergency Response Guidebook?
6. Are Hazmat employees qualified to perform adequate inspections of vehicle and cargo?
7. Are HM employees trained to determine compatibility of mixed loads/suitability of vehicles?
8. Do Hazmat employees have adequate knowledge of correct equipment usage ?
9. Are drivers trained in state law, federal regs and company policy regarding safe driving?
10. Are drivers aware of the hazards of railway crossings?
11. Are drivers aware of regs & conditions which require that drivers remain with their vehicles?
12. Do drivers practice defensive driving techniques?
Tips for Management:
* Introduce refresher training for Hazmat employees.
* Initiate a recognition program for well-trained Hazmat employees.
* Training programs should include cargo-specific training.
* Introduce specialized training for tank truck drivers.
* Arrange for drivers to gain non-Hazmat hauling experience before hauling HM.
Tips for Hazmat Employees:
1. Do not take shortcuts or vary from established hazardous materials handling procedures.
2. Practice safe driving techniques at all times.
3. Prior to trip, get adequate rest and nourishment.
4. Maintain your high driving alertness by taking rest stops, avoiding caffeine and reducing cab temperature.
5. Reduce vehicle speed, especially on ramps and curves.
6. Many accidents occur while crossing train tracks; do not shift gears when crossing train tracks.
References: 49 CFR Parts: 172 Subpart H; 177.848; 383 Subpart G; 392; 397. A8, A9, A10, B1, B2, B4, B11, B12, C2, C11, C12, G1, G3, G4, G6, G12, G13, G14.
LOADING/UNLOADING TRAINING T2
COUNTERMEASURE
Objective: To reduce the frequency of Hazmat loading and unloading incidents by training personnel in the correct procedures.
Description: Many incidents involving hazardous materials occur during the loading or unloading phases of transportation. Training in correct handling procedures as well as educating personnel about the potential dangers of hazardous materials may help reduce the frequency of these occurrences.
Questions for Management:
1. Are personnel familiar with the properties and characteristics of the materials they are handling?
2. Is training available for personnel involved with loading and unloading hazardous material?
3. Are personnel trained in grounding and bonding requirements and procedures?
4. Are personnel aware of correct compressed-gas cylinder pickup procedures?
5. Are there established procedures for switch loading?
6. Are drivers trained and encouraged to recognize packages which are not authorized or packages
that may be defective?
7. Is a closed cargo space used for all hazardous materials (unless fire and water resistant)?
Tips for Management:
* Train personnel in safe loading techniques and to be alert for pinch points.
* Train personnel to turn off the truck engine during loading and unloading whenever possible;
if the engine is required for pumping, it should be turned off while hoses are being connected
and disconnected.
* Personnel involved in confined-space loading/unloading activities should be trained in
confined-space entry hazards.
Tips for Hazmat Employees:
* Check safety guide before loading or unloading begins.
* Remove ignition keys prior to loading/unloading to avoid "pull-away" incidents.
* Be careful not to overfill or overload tanks.
* Be careful when handling cylinders and packages of hazardous materials.
* Handle empty drums with the same caution as full drums.
* Do not overload closed cargo spaces; allow air to circulate.
* Close all access flanges and valves before moving and allow adequate relaxation time.
References: 49 CFR Parts: 172 Subpart H; 173.24; 173.29; 173.30; 392.9; 393 Subpart I. A11, C2, C11, C12, G1, G2, G4, B1, B5, T2.
CLASSIFICATION TRAINING T3
COUNTERMEASURE
Objective: To reduce the frequency and/or severity of hazardous materials incidents by training Hazmat employees to properly classify hazardous materials.
Description: The shipping process begins with a desire or need to ship a material. Subsequent shipping activities, such as packaging, labeling, marking, handling, placarding, etc., are affected by the characteristics and potential hazards of the material being offered. Training Hazmat employees in proper classification procedures will promote accurate classification and safety throughout the hazardous materials transportation process.
Questions for Management:
1. Are all Hazmat employees involved in hazardous materials classification trained properly?
2. Are updated reference materials regularly provided to Hazmat employees?
3. Are refresher courses offered to Hazmat employees?
Tips for Management:
* Participate in training which is appropriate.
* Register Hazmat employees in training courses which include compulsory evaluations.
* Encourage and support Hazmat employee training by recognizing successful completion of
training courses.
* Encourage Hazmat employees to share training materials and tips learned at training courses.
* Encourage Hazmat employees to help develop each others' skills.
Tips for Hazmat Employees:
* Become familiar with types of classifications for hazardous materials.
* Inform management if/when you feel that additional training is needed.
References: 49 CFR Parts: 172 Subpart H. C11, G3, G12, G13, B8.
PLACARDING TRAINING T4
COUNTERMEASURE
Objective: To communicate the potential hazards of transported materials by training the driver and loading/unloading personnel in correct hazardous materials placarding.
Description: In the event of an emergency situation, it is critical that the primary hazards associated with a shipment be communicated to emergency response personnel and to other people in the immediate area. Placards enable the hazards of a cargo to be identified from a distance. Personnel who are properly trained may detect placarding procedures which do not comply with regulations and thereby avoid dangerous and costly errors at an emergency scene.
Questions for Management:
1. Are Hazmat employees aware of when to placard vehicles?
2. Are Hazmat employees trained and able to properly placard vehicles when necessary?
3. Does the schedule permit the proper placarding of vehicles by Hazmat employees?
Tips for Management:
* Train personnel in the importance of placarding.
* Encourage use of specific placards when necessary.
Tips for Hazmat Employees:
* Know what to do with the hazardous materials cargo in case of an emergency situation.
* Become familiar with the properties of your hazardous materials cargo; placards provide only
general information, particularly with respect to mixed loads.
* Use material-specific placards whenever possible; for example, avoid using the general placard
for "flammable liquid, not otherwise specified" if a more specific placard is appropriate.
References: 49 CFR Parts: 172 Subpart F; 172.600; 172 Subpart H; 173.22; 177.816;397. B12, C12, G6, G12, G13, B8, B9.
SHIPPING PAPERS TRAINING T5
COUNTERMEASURE
Objective: To ensure correct identification of shipped hazardous materials by training employees to interpret shipping papers correctly and to recognize discrepancies, omissions and errors in the documents.
Description: Shipping papers are the most important source of information available to identify the hazardous materials involved in an incident. The first emergency response is often determined by the information contained in the shipping papers. Training employees to recognize irregularities and errors in shipping papers is necessary to help ensure that shipping papers can properly inform emergency responders and everyone else.
Questions for Management:
1. Are employees trained in the importance and use of shipping papers?
2. Are employees able to recognize discrepancies between the materials loaded on a truck and the
items shown on the shipping papers?
3. Are drivers aware of where shipping papers should be carried & how they are to be handled?
Tips for Management:
* Perform regular audits of shipping papers and cargo to ensure that both company personnel and clients
are properly completing papers.
Tips for Hazmat Employees:
* Review shipping papers carefully before pulling away.
* Become familiar with the properties of your cargo since shipping papers do not provide
complete information.
* Be familiar with the proper emergency procedures and the people to contact in case of an emergency.
* Know what to do with the cargo in case of an emergency situation.
References: 49 CFR Parts: 172 Subpart C; 172.704; 177.817; 397.19. A8, A11, B12, G3, G12, G13, B8, B9.
LABELING TRAINING T6
COUNTERMEASURE
Objective: To promote accurate identification and recognition of the potential dangers of hazardous materials packages by training Hazmat employees in the correct labeling procedures.
Description: The type of material shipped determines, among other things, handling procedures, placards and emergency response. Correct labeling is important for identifying the hazards of a material both on a routine basis as well as in emergency situations. Labels are also used to check shipping papers and to assist loading and unloading personnel to safely distribute mixed loads.
Questions for Management:
1. Are personnel trained in interpreting labels?
2. Are personnel trained in checking labels against shipping papers and placards?
Tips for Management:
* Emphasize the value of Hazmat labels both in routine and in emergency situations.
Tips for Hazmat Employees:
* Know what to do with the cargo in case of an emergency situation.
* Do not rely on package labels in emergency situations, but rather refer to shipping papers and
safety literature to become familiar with the properties of your cargo since package labels provide
only limited information.
References: 49 CFR Parts: 172 Subpart E; 172.704; 177.817. B12, C11, G12, G13, B8, B9.
MARKING TRAINING T7
COUNTERMEASURE
Objective: To promote correct package marking and to improve the conspicuity of hazardous materials cargo by training Hazmat employees in correct package marking procedures.
Description: A package containing hazardous materials must be marked with either the consignee's or the consignor's name and mailing address as well as proper shipping name, identification number and certain warnings if applicable. Package markings contain information which may be important in certain emergency situations, such as when the package is separated from the vehicle. In addition, the information provided in package markings should agree with that given in shipping papers.
Questions for Management:
1. Are personnel trained in checking package markings against shipping papers and placards?
2. Are personnel trained in interpreting package markings?
Tips for Management:
* Educate personnel about the value and utility of package marking in routine and emergency situations .
Tips for Hazmat Employees:
* Familiarize yourself with the properties of the cargo because package markings provide only
limited information.
* Refer to shipping papers and safety literature for appropriate precautions and procedures.
* Know what to do with the cargo in case of an emergency situation.
References: 49 CFR Parts: 172.300; 172.326; 172.328; 172.704; 177.826. A11, B12, C11, G3, G12, B8, B9.
PACKAGING TRAINING T8
COUNTERMEASURE
Objective: To reduce the frequency and/or severity of hazardous materials incidents by adequately training Hazmat employees in proper packaging procedures.
Description: Adequate packaging is a critical activity in the hazardous materials transportation process. Packaging is the first line of defense for containing hazardous materials in the event of an accident, yet inadequate packaging is commonly cited as a factor which contributed to a hazardous materials incident. Adequately training Hazmat employees in proper packaging may reduce the number of shipments prone to package failure.
Questions for Management:
1. Does company philosophy encourage employees to put in extra effort to "do it right?"
2. Has management committed sufficient resources to Hazmat employee training?
3. Is management familiar with applicable regulatory guidelines regarding Hazmat employee training?
4. Are Hazmat employees adequately trained?
5. Are Hazmat employees encouraged or required to participate in training programs?
6. Are Hazmat employees who successfully complete training courses publicly recognized?
Tips for Management:
* Register Hazmat employees in approved training courses which include competency evaluations.
* Provide opportunities for Hazmat employees to take refresher courses.
* Encourage Hazmat employees to share training materials and tips learned in training courses.
* Encourage Hazmat employees to help develop each others' skills.
* Periodically monitor packaging operations for compliance with company policy and applicable regulations.
Tips for Hazmat Employees:
* Become familiar with appropriate packaging for various hazardous materials.
* Inform management if/when you feel that additional training is needed.
References: 49 CFR Parts: 172 Subpart H; 173; 178; 180. A3, C11, C12, G3, G9.
EMERGENCY RESPONSE TRAINING T9
COUNTERMEASURE
Objective: To prevent a hazardous materials incident from becoming more serious by training personnel to respond quickly and appropriately.
Description: It is crucial that the response to a hazardous materials incident be rapid and proper. An improper emergency response can result in an incident far worse than the initial incident. Properly training personnel to respond to incidents may reduce the number of Hazmat incidents that are aggravated by improper first responses.
Questions for Management:
1. Are personnel trained in correct emergency response procedures?
2. Are there pre-planned emergency responses for given situations?
3. Are personnel evaluated regularly for proper emergency response procedures?
4. Are Hazmat employees encouraged to learn such emergency responses?
Tips for Management:
* Coordinate emergency response efforts with those of local authorities.
* Establish company emergency response teams.
* Use exercises and drills as emergency response training aids.
* Train employees in the proper use of personal protection equipment.
* Train employees in decontamination and disposal procedures.
Tips for Hazmat Employees:
* As a general rule, keep out of line with the ends of a tank undergoing fire exposure.
* Do not perform an aggressive response unless appropriate procedures have been established,
correct equipment is available and the material properties are known.
References: 49 CFR Parts: 172 Subpart G; 172 Subpart H. B12, G1, G10.
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