In yesterday’s Advisor, we reviewed training requirements for certain workers involved with asbestos-containing material. Today, we offer steps for developing a training program that meets U.S. Department of Transportation (DOT) training requirements for employees who handle hazardous materials.
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DOT’s Hazardous Materials Regulations (HMR) require that hazardous material (hazmat) employees receive “adequate training” for their specific job duties. As a hazmat employer, you are left in the dark as to what “adequate training” actually means. As a matter of fact, the DOT has written a letter of interpretation that states the agency’s position on the meaning of “adequate training” for hazmat employees. The letter states that responsible hazmat employers, either individually or through industry associations, are best qualified to determine the training needs of their employees. So, states the DOT, “No attempt has been made to specify the level and duration of training or testing.”
7 Steps for an Effective HazMat Training Program
Given the sketchiness of the hazmat training regs, DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) periodically publishes guidance material to assist hazmat employers in meeting the requirements to train employees. These steps were gleaned from a PHMSA guidance document concerning training programs.
Step 1: Conduct a needs assessment. Begin by determining the level of awareness hazmat employees have about hazardous materials and the HMRs. Find out if the training employees have already received is adequate for the tasks they are now performing. This is frequently an issue in smaller companies where an employee may be required to fill in for coworkers on regulated activities.
Similarly, if the company’s operations have changed since the last round of training, determine if new employee training to accommodate the changes has occurred.
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Step 2: Select a training tool. There are four basic training delivery methods: Web-based, computer-based, classroom, and hands-on training. Decisions on which of these or which combination is most appropriate will depend on many factors, including cost, suitability for the hazmat employee and the employee’s hazmat responsibilities, language proficiency, whether employees can be self-directed, and qualifications of the instructor.
Step 3: Evaluate the effectiveness of the training program. A training program is only as good as the results it produces. You should query employees about how they benefited from the training. You should also observe employees after training to determine how lessons have been incorporated into performance. Results of interviews and observation should be documented and incorporated, if necessary, into subsequent training.
Step 4: Don’t stop with training. Develop a safety culture that encourages training as part of daily and typical tasks and operations. You should encourage your employees to identify problems at early stages without fear of retribution or retaliation.
Step 5: Assign a training manager. One or more employees with knowledge of the HMRs and experience receiving and providing training can ensure that training continues to be conducted as required and with a high success rate. A training manager should be given the time and resources to effectively manage training.
Step 6: Make a plan. Don’t make important training decisions only when a hazmat employee is hired or operations change. A plan need not be long and complicated. It can start with a simple statement of purpose and the benefits that can derive from thorough and regular training that is appropriate to the employee, the job function(s), and the company and its resources. The plan should include specific directions on how the effectiveness of training is evaluated and methods to improve the program, if necessary. Directions on completing administrative tasks, such as recordkeeping and maintaining a schedule of both required and discretionary actions, should also be included.
Step 7: Make sure employees understand the training. Training information must be presented clearly and accurately and in a manner that can be understood by employees of varying literacy and language skills.
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The information in this issue comes courtesy of our sister publication, Environmental Daily Advisor.