Between acids, glues, paints, pesticides, solvents, petroleum products, and heavy metals, hazardous materials can be found in countless facilities throughout various industries. Ubiquitous as they are, however, such substances can be difficult to manage. We’re not talking about paperclips or sticky notes. As you already know (if you’ve been reading along with this series so far), organizations must follow rigorous federal and state regulations when using, labeling, storing, and training their workers on hazardous materials.
The same logic applies when it comes time to pack up and move those materials. You can’t simply load barrels of chemicals onto a U-Haul or stuff some asbestos into a bubble mailer and toss it in the nearest mailbox.
To stay on the right side of the law and keep your workers protected, you need to ensure that any facility you operate abides by the following US Department of Transportation (DOT) rules and guidelines:
1. Train All Workers Within 90 Days of Hire
DOT requires “initial and recurrent training of all employees who perform work functions covered by the Hazardous Materials Regulations.” That means you need to train any hazmat transportation worker 1) shortly after hiring the individual and 2) periodically thereafter (i.e. every three years or any time a worker’s job function changes).
DOT-mandated training can be divided into 3 general topics, 2 of which apply to your entire hazmat transportation team:
- General awareness—overall hazardous materials handling, storage, and communication rules
- Safety and security—the risks associated with hazardous materials, along with emergency response procedures
- Function-specific training
Numbers 1 and 2 apply to your whole team; number 3 varies from role to role. Depending on a worker’s role, function-specific training may cover shipping papers, marking and labeling, placarding, packaging, loading and unloading, or a combination of topics. For more information, click here.
All workers involved in the transportation of hazardous materials should be trained and certified as soon as possible, and no later than 90 days after they join your organization.
2. Maintain a 24-Hour Emergency Response Phone Line
Your organization’s obligations don’t end once your hazardous materials hit the road. DOT requires anyone who “offers a hazardous material for transportation” to “provide an emergency response telephone number, including the area code, for use in an emergency involving the hazardous material.”
Your company’s support line may not cut it. DOT specifies that an emergency response number must…
- be monitored as long as the hazardous material is in transport;
- belong to someone “who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who possesses such knowledge and information”;
- be listed on a shipping paper.
To fulfill this requirement, many organizations choose to outsource their emergency response lines to third-party providers.
3. Document Everything
As always, make sure to keep detailed, thorough, and accessible records for all people and things associated with the transportation of hazardous materials. Be ready to produce workers’ DOT Hazmat certifications, information on emergency response protocols, and other compliance documents at a moment’s notice.