Training: U.S. Department of Transportation (DOT) International Air Transport Association (IATA)

Transportation Training for Land, Sea, and Air

Not sure if you or your employees need training under U.S. Department of Transportation (DOT) International Air Transport Association (IATA), International Civil Aviation Organization (ICAO) , and International Maritime Organization (IMO) regulations?

U.S. DOT training rules apply to any company which performs any function in any way regulated by the US DOT Hazardous Materials Regulations (HMR). This includes any company which:

  • Offers hazardous material for transportation;
  • Packages, marks, or labels hazardous material for transportation;
  • Loads or unloads hazardous materials;
  • Transports hazardous material,
  • Receives and forwards packages containing hazardous materials;
  • Manufactures packaging for use in hazardous materials transportation; or
  • Tests hazardous material packaging.

There are no exemptions provided for small companies. Even a self-employed person who ships hazardous materials as part of his job must provide training for himself.

Each “hazmat employer” is required to train each “hazmat employee”. A hazmat employee is anyone who directly affects hazardous materials transportation safety. A variety of personnel can meet the definition of a “hazmat employee”, including an employee who:

  • classifies materials
  • determines proper shipping descriptions
  • determines ORM-D status
  • assigns packing groups
  • identifies chemical or physical properties of hazardous materials
  • determines emergency response information for hazardous materials shipments
  • selects, purchases or prepares packages
  • determines any markings to be applied to a package
  • determines which labels and how many must be applied to the package
  • determines placarding requirements
  • completes and signs shipping papers
  • selects carriers or modes of transportation
  • loads, unloads, handles, or works around hazardous materials (warehouses, loading docks)
  • responds to damaged containers, spills, or leaks and reports incidents operates any vehicle or equipment used to transport hazardous materials

In addition, supervisors of hazmat employees must also be trained.
DOT requires certain categories of “hazmat employee” training.

1. General Awareness Training: All hazmat employees must be given a general understanding of the entire hazardous materials transportation program

2. Function-Specific Training: Each hazmat employee (by job function) must be trained on the requirements for performing transportation-related duties.

3. Safety Training: Persons handling or potentially exposed to hazardous materials during the cycle of transportation (e.g., drivers, loaders, loading dock workers, warehousemen, etc.) must be trained in safe handling and emergency response procedures applicable to the hazards to which they may be exposed.

4. Security Awareness Training: Each hazmat employee must be trained to recognize and protect against potential terrorist threats involving hazardous material shipments.

5. Security Plan Training: For operations that require a written security plan, each hazmat employee must also be trained in company security objectives, organizational structure and specific procedures, responsibilities or actions required from them.

6. Driver Training: There are additional specific requirements for training of hazardous materials drivers.

Hazmat employee training must be updated whenever DOT issues any new or revised rule that is applicable to the duties of a particular employee. The training must be completed prior to performing a function affected by the new or revised rule. Hazmat employee training must be conducted in its entirety at least every three years.

What about international shipments?

The DOT HMR regulations apply to domestic hazardous materials shipments. However, when shipping hazardous materials within or from the U.S. by air or water, such shipments must comply with international (IATA/ICAO or IMO) “dangerous goods” standards and rules. The rules of IATA (The International Air Transporters Association), ICAO (The International Civil Aviation Organization), and IMO (The International Maritime Organization) require training of employees who have duties relating to international shipments of dangerous goods.

Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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