This document provides an overview of hazardous materials regulations training requirements. It discusses the regulatory bodies that govern hazardous materials transportation, including OSHA, DOT, EPA, and NFPA. It outlines the jurisdictions of OSHA and DOT, with DOT having jurisdiction over in-transit operations and loading/unloading, while OSHA covers workplace safety. The training will focus on DOT but also cover OSHA and EPA requirements. It will review hazard classes, the hazardous materials table, shipping papers, placarding, and emergency response procedures to help prevent accidents involving hazardous materials transported.
3. Regulatory bodies that govern the transportation
of hazardous materials
OSHA-concerned with protecting the employee
DOT-concerned with the safe transport of hazardous materials
(via air, rail, roadway)
EPA (DEP)-concerned with protecting the environment
NFPA 58 concerned with bulk storage of Propane
All require written plans, formal training, emergency response
procedures
4. OSHA or DOT Jurisdiction
OSH Act
• Section 4(b)(1) of the OSH Act states that OSHA
does not have jurisdiction over health and safety
if another Federal agency exercises its statutory
authority in this area.
U.S. courts interpret the OSH Act using the “gap theory”
or “hazard-by-hazard” approach:
• If DOT has a regulation that would reduce or eliminate
the workplace hazard, DOT regulations apply.
• If DOT does not have a regulation to address the
hazard, OSHA regulations apply.
5. OSHA or DOT Jurisdiction
•
DOT has jurisdiction for:
– In transit operations between destination points, including read justing and
securing the load.
– Proper handling of hazardous materials during loading and unload ing
vehicles and rail cars according to the Hazardous Materials Regulations (49
CFR 171-180).
•
OSHA has jurisdiction for:
– Actions associated with loading and unloading the vehicle or rai lcar at
destination points where DOT does not address a safety or health hazard.
– Response to hazardous waste emergencies.
6. Overall objectives of today’s training presentation
Will focus primarily on DOT training but will also encompass the main
requirements of OSHA & EPA training requirements regarding the
handling and transporting of hazardous materials
Help to prevent unplanned releases and accidents involving the
hazardous materials transported by this operation
Provide information regarding the hazards of the chemicals/hazardous
materials that you may be exposed in your workplace.
7. Scope of training
You should:
Be familiar with the general provisions of the Hazardous materials
regulations (HMR) part 172, subpart H (formerly HM126F)
Be able to recognize and identify the hazardous materials as they
apply to your job function
Have knowledge of emergency response information, self protection
measures, and accident prevention methods and procedures
8. DOT required Haz Mat employee training shall include
General awareness/familiarization training
Function-specific training
Safety training
Driver training
• Specific cargo tank training
Security awareness
10. AREAS THAT WE WILL COVER RELEVANT TO THESE
PRODUCTS ARE:
Hazardous materials table
North American Emergency guide book (guide sheet 128)
Shipping papers
Placarding
Highway carrier requirements
Emergency response procedures
11. Areas we will not cover today
Packaging
Labeling
Transport by Air
Transport by Rail
Hazardous materials other than propane,oil, diesel, kerosene
*These are topics that are included in the requirements but do not
apply to your operation
12. HAZMAT EMPLOYEE (49 CFR 171.8)
A HAZMAT employee is a person employed by a
HAZMAT employer and who, in the course of
employment, directly affects hazardous materials
transportation safety. This term includes owneroperators of a motor vehicle that transports hazardous
materials in commerce.
13. Hazmat Employee (includes owners)
Loads, unloads, or handles hazardous materials
Manufactures, tests, reconditions, repairs, modifies, marks, or
otherwise represents containers, drums or packaging as qualified for
use in the transportation of hazardous materials
Prepares hazardous materials for transportation
Is responsible for safety of transporting hazardous materials
Operates a vehicle used to transport hazardous materials
15. The shipper
(owner, driver, dispatcher, fleet manager, office)
Person or company sending the
hazmat from one place to another:
Must assign proper shipping name,
hazard class, identification numbers,
correct type of packaging, correct label
and marking on placards, correct placards
Properly packages the hazmat
Prepares shipping papers
Certifies on the shipping papers that
they have prepared shipment properly
16. The carrier
(driver, fleet manager, company owner)
Transports shipment to
destination
Ensures that product has
been correctly named,
labeled and marked for
shipment
Reports any accidents or
incidents to the proper
government agency
17. The driver
Ensures that shipper has
properly identified, marked
and labeled product
Must refuse leaking
shipments
Attaches appropriate
placards
Delivers products safely &
obeys all rules and
requirements
Keeps shipping papers in
proper place
18. General Awareness
Must be familiar with the requirements of HM training
requirements
Hazard communication training
• Must be able to recognize HM
• Must know hazards of chemical to which you may be
exposed (hazard classes)
• Must know what to do in the event of an emergency or
unplanned release
19. Function-specific training
Must be familiar with the standards as they apply to your
specific job
These will vary depending on the individual’s specific job
function
20. Safety training
Must include:
Emergency response information required by subpart G of part 172
Measures to protect the employee from the hazards associated with
the HazMat to which they may be exposed in the work place, including
specific measures the hazmat employer has implemented to protect
employees from exposure
Methods & procedures for avoiding accidents involving hazardous
materials
21. Driver training
Training must include the following subjects:
Pre-trip inspection
Use of vehicle controls and equipment, including operation of
emergency equipment
Operation of vehicle
• Turning, backing,braking, parking,handling, effects of braking,
dangers of maneuvering through curves, effects of speed, dangers
of weather & road conditions, and high center of gravity
Procedures for maneuvering tunnels, bridges and railroad crossings
Requirements pertaining to attendance of vehicles, parking, smoking
routing and incident reporting
Loading and unloading procedures
Packaging and securing load
22. Operators of Cargo Tanks
Training for cargo tank drivers must include:
Operation of emergency control features of the cargo tank
Special handling characteristics
• High center of gravity, fluid-load subject to surge, effects of fluidload surge on braking, characteristic differences in stability
among baffled, un-baffled and multi-compartmented tanks, effects
of partial loads on vehicle stability
Loading & unloading procedures
Properties and hazards of the materials transported
Retest and inspection requirements for cargo tanks.
26. Hazardous Materials
“Materials that are capable of posing an unreasonable risk to
health, safety, & property when transported in commerce.”
A material is considered to hazardous if it:
•Meets one or more hazard class definitions
•Is a hazardous substance, hazardous waste, marine pollutant,
or elevated-temperature material.
27. Hazardous Materials Table
Lists and classifies those materials which the DOT has
designated as hazardous materials for purposes of
transportation and prescribes the requirements for shipping
papers, package marking, labeling, and transport vehicle
placarding applicable to the shipment and transportation of
those hazardous materials.
29. The Hazardous Materials Table
Lists materials alphabetically by proper shipping name
Consists of 10 major headings:
•
Symbols
•
HM descriptions & proper shipping names
•
Hazard class or division
•
Identification numbers
•
Packaging group assigned to the material
•
Label codes
•
Special provisions
•
Packaging
•
Quantity limitations
•
Vessel Stowage
30. Symbols
+ - “Fixes”(means you can’t change it) the proper shipping name, hazard class or
division and packing group in columns 2, 3 &5
A – means that the material is only regulated if offered for and/or transported by air,
unless the material is a hazardous substance or hazardous waste. In that case, it’s
regulated in all modes of transportation * see definitions
D- Identifies proper shipping names describing materials for domestic transportation.
G-identifies n.o.s. and generic proper shipping names that require the addition of one
or more technical names
I-identifies proper shipping names describing materials for international transportation
W-means material is regulated only if transported by water unless the material is a
hazardous substance or hazardous waste
31. Nine hazard classes
Class 1 - Explosives
Class 2 - Gases
Class 3 - Flammable liquids
Class 4 - Flammable solids
Class 5 - Oxidizing substances and Organic Peroxides
Class 6 - Poisons/Toxic Materials
Class 7 - Radioactive materials
Class 8 - Corrosive materials
Class 9 - Miscellaneous hazardous materials
39. When transporting Empty Cargo Tanks
Shipping papers are still required if a cargo tank has been
emptied, but not cleaned of the hazardous residue.
(For Propane dealers) When transporting ASME tanks with a
capacity of 125 gallons or greater to or from a customer’s
location, they must not contain more than 5% propane during
transport.
40. Shipping papers
May be in any form or format as long as it contains the
information required by the HMR in the correct sequence
Must contain basic description & any additional
descriptions or entries
Must be legible & printed in English
Must accurately communicate the hazards of the materials
being transported
Most must be certified but certification is not required for
materials transported by cargo tank
41. Shipping papers
Must be readily available & visible to a person entering the
driver’s compartment
Must be clearly distinguishable
Must be within immediate reach of the driver while restrained by
lap belt
When the driver is not in vehicle must be in holder on inside of
door or on driver’s seat
42. 24-hour Emergency Response number
Required on all shipping papers
Must be monitored at all times while the material is in
transportation, including storage incidental to
transportation
Contact person must be capable of providing emergency
response & incident mitigation information immediately,
upon request
43. Emergency Response Information
The shipper must also provide emergency response information
for each hazardous material listed on the shipping paper
44. Emergency Response Information
Information about hazardous materials & the necessary
immediate precautions & actions to take in the event of a spill or
leak are required
Must carry in the same manner as the shipping papers
50. Placards
There are two placarding tables:
When determining which placards must be used and what
options are available, both placarding tables must be
considered
51. Placards
Must clearly communicate the hazard of the material being
transported
Must have no visual competition
Must be readily visible from the direction it faces
Be on all four sides of vehicle (each side and each end)
placed so words are level and read from left to right
Must be located clear of appurtenances and devices, away
from dirt and water & at least three inches away from any
other markings
Words and/or numbers must be displayed horizontally
52. Placard modifications
The word “gasoline” may be used in place of the word
“flammable” on cargo tank transporting gasoline
Fuel oil (in cargo tank) may be used in place of word
“combustible”
53. Placard
Placarding is responsibility of shipper and carrier
(that includes driver).
If the required placard is missing, or damaged, no matter what
the reason, the shipment must not be transported.
57. HMR, part 177
“Carriage by Public Highway”
Requires motor carriers to train employees in the
prescribed regulations
Additional specific training is required for operators of
cargo tanks or vehicles with a portable tank with capacity
of 1,000 gallons or more
58. Motor Carriers
Must also comply with the
Federal Motor Carrier Safety
Regulations (FMCSR) & refer to
driver qualifications, hours of
service, equipment standards
and operational requirements.
US DOT reps may inspect all
motor carrier records,
equipment, packaging &
containers -- that may affect the
safe transportation of hazardous
materials
59. Loading and unloading
(HMR 177.834)
Attendance requirements
• A cargo tank must be attended by a qualified person at
all times when it is being loaded
• The person who is responsible for loading the cargo
tank is also responsible for ensuring that is so
attended
60. Loading & Unloading
A person “ attends” the loading or
unloading of a cargo tank if,
throughout the process:
He/she is awake/alert
Has unobstructed view of the cargo
tank
Is within 25 feet of the cargo tank
Knows the hazards of the material
61.
62.
63.
64.
65. Safety Measures
No smoking on or near vehicle
No spark producing tools
Use caution with tools so as not to damage packages,
containers, or their closures
Do not load flammable materials in a cargo space that
has a heater unit
67. Pre-Trip Inspection
“No motor vehicle shall be driven unless the driver
thereof shall have satisfied himself that the following
parts & accessories are in good working order, nor shall
any driver fail to use or make use of such parts and
accessories.” (FMCSR part 392.7)
75. Baffles
Dividers with holes in them, designed to
slow down the front-to-back surge. They do
not have much effect on side-to-side surge
76. SURGE:
The movement of the liquid from the front to the back,
and from side to side.
Determined by two major factors:
Amount of liquid in the tank
Design of the tank
77. Countermeasures for dealing with Surge
Maintain 12 to 15 second eye lead time Always slow down
before entering curves - posted limit is for cars not tankers
Accelerate gently through the curve
Avoid sudden stops whenever possible by maintaining a good
cushion of safety around the vehicle.
78. Three factors that can cause a skid
Oversteering
Overbraking
Overacceleration
79. Emergency maneuvers
It is almost always better to steer to avoid an emergency
than to brake to avoid one
Don’t brake while making an emergency turning
maneuver.
If you must brake, use stab or controlled braking
When using stab braking, release the brakes as soon as
the wheels lock up, and then apply the brakes hard again
If the steering tires lock up, you will continue straight
regardless of how you turn the wheel
If you must leave the roadway, slow to 20 mph, if
possible, before applying brakes
82. Objectives for this section
Review OSHA HAZWOPPER requirements
Review the emergency operating procedure requirements
Review some emergency operating procedures
Review spill prevention measures
83. OSHA first responder awareness level
First responders are individuals who are likely to witness or discover a
hazardous material release & have:
• an understanding or what hazardous chemicals are & risk associated
with them;
• an understanding of potential outcomes of HM emergency
• the ability to identify the hazardous materials
• understanding the role of first responder in the emergency response
• plan, including site security & control
• ability to realize need for additional resources & make appropriate
• notification to communication center
84. First Responders Operations level
Knowledge of basic hazard & risk assessment techniques
Know how to select & use proper personal protective equipment
provided
Has understanding of basic hazardous materials terms
Knows how to perform basic control, containment and/or confinement
(dam, dike, divert)
Knows basic decontamination procedures
Understands relevant SOP & termination procedures
85. Basic terms
Flammable liquid-any liquid that has a flash point 140F or less
Flash point-temperature where the liquid will ignite, detonate, explode
86. North American Emergency guidebook
Contains information on hazardous
materials
Accepted by emergency response
information
Driver should have individual guide
sheets or should know which guide
sheets apply to the product being
carried
In the event of accident, if possible
take guide sheet & shipping papers
and get away from vehicle
Provide ER info to first responders
87. North American
emergency guide sheets provide info in the
following areas:
Potential hazards
• Fire or explosion
Emergency response
• Fire
• Health
• Public safety
• Spill or leak
• First aid
• Protective clothing
• Evacuation
• Fire
89. Potential hazards of petroleum products
Guide Sheet 128
<>FIRE OR EXPLOSION· HIGHLY FLAMMABLE: Will be easily ignited
by heat, sparks or flames.
· Vapors may form explosive mixtures with air.· Vapors may travel to source
of ignition and flash back.
· Most vapors are heavier than air. They will spread along ground and collect
in low or confined areas (sewers, basements, tanks).
· Vapor explosion hazard indoors, outdoors or in sewers.
· Those substances designated with a "P" may polymerize explosively
when heated or involved in a fire.
· Runoff to sewer may create fire or explosion hazard.
· Containers may explode when heated.
· Many liquids are lighter than water.
· Substance may be transported hot.
90. Potential hazards of Propane-Guide Sheet 115
<>FIRE OR EXPLOSION· EXTREMELY FLAMMABLE.
· Will be easily ignited by heat, sparks or flames.
· Will form explosive mixtures with air.
· Vapors from liquefied gas are initially heavier than air and spread
along ground.
· Vapors may travel to source of ignition and flash back.
· Containers may explode when heated.
· Ruptured cylinders may rocket.
93. Emergency Operating Procedure requirements
A comprehensive written emergency operating procedure must
be developed for all transfer operations and hazmat employees
who perform unloading functions must be trained in its
provisions.
The emergency operating procedure must be prominently
displayed in or on the cargo tank motor vehicle
94. Emergency responses for leaks during transit
If the problem is before the nozzle, then SHUT OFF THE
NOZZLE.
If the problem is with the nozzle, then PUSH THE STOP
BUTTON at the meter.
If the problem is with the tank, then USE CONTAINMENT
MEASURES TO STOP OR SLOW THE LEAK, THEN CALL
FOR HELP.
If the truck is on the roadway, try and pull OUT OF THE FLOW
OF TRAFFIC but DO NOT drive beyond the nearest point at
which safe removal of the fuel can be made.
Warn nearby person of fire hazard. Extinguish nearby open
flames. DO NOT SMOKE!
Report the spill to your company emergency response
coordinator
95. Emergency response procedures in transit
If possible:
Dam, Dike or Divert spilled product, keep it away from storm or
sewer drains, catch basins and waterways.
Contain product using booms, pigs, absorbent pads or
gravel/soil embankments.
Secure site until remediation and emergency response personnel arrive on the
scene.
However, never take action unless you have
been properly trained (awareness level and
operators level) and directed by your employer
to do so.
96. If a spill occurs during delivery or service call
Shut off the supply
Look around for sump pumps, drains or holes ,or cracks in
floors and foundation-keep oil away from these areas
Contain spill by using oil pads, booms or speedy dry
Use plugs or patch on tanks if possible
Create a vacuum in tank by using a fill cap or plastic bag
and placing over fill.
Say as little as possible to homeowners, never admit
liability!
97. REPORT ALL SPILLS
If spill happens during normal business hours: report to office
If after hours, call SPLASH hotline direct
98. Be prepared to tell them
Extent of spill-quantity
Location of the spill
• Address
• Inside home, outside home, on the road
When it happened
If in the home, has the homeowner been notified
If on the road, have any emergency responders
arrived on the scene
Is the product contained or not
100. Most common spill claims
Tank over-pressurization
• blocked or partially blocked vent
• pumping too fast for vent pipe size
Misdelivery:
• disconnected fill pipe
• defective tank
• wrong address
Leaking hoses
101. Recommended spill prevention measures
•Always employ No Whistle-No fill policy
•Double check address & location of fill
•NEVER LEAVE THE FILL PIPE during delivery! Stay
alert.
•Pre-inspect new customers whenever possible
•Use reasonable pumping rates-no greater than 70gpm
•Check hoses for wear on regular basis
•Pull hose from shoulder, never drag nozzle on ground
•If you suspect anything is wrong. STOP the delivery and
call dispatch
102. Safety really is No accident!
Famous last words:
“It’s just common sense”
“That could never happen to me”
“It’s not my fault…the other guy should have removed that
disconnected fill”
“But I had the right of way”
“I’ve been doing it this way for years!”
Reference Information
The following letters of interpretation provide information regarding safety and health jurisdiction for OSHA and DOT :
July 10, 1989 - Review of Policy on Section 4(b)(1) of the Act: Pertains to the DOT’s Motor Carrier Safety Act and related statutes, a review of OSHA case law relating to truck drivers, and a summary of applicable 4(b)(1) case law including those upholding the “gap theory” and “hazard-by-hazard” approach.
November 9, 1990 - Jurisdiction issues involving the Southwest Transportation Company, Inc.
April 1, 1991 - Jurisdictional Issue - Southwest Transportation
August 2, 1991 - The working environment of railroad train environment
This first section is an overview of the material that will be presented. It reviews the requirements of the standard.
The regulation states that each hazmat employee must be provided general awareness/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. In other words, first you have to relate what the standard says and then you must train the driver/employee in the hazards of the chemicals that they may be exposed to in the course of conducting their job duties.
HM 171.8 definitions:
Hazardous material means a substance or material, which has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated. The term includes hazardous substances, hazardous wastes, marine pollutants, and elevated temperature materials
Hazardous substance –complicated listing but specifically says that it does not include crude oil or any fraction thereof, natural gas, Liquefied natural gas or synthetic gas usable for fuel.