Potentially considered a strange obsession to most, my favorite environmental compliance topic is hazardous materials shipping inclusive of hazardous waste. The eyeroll I get when sharing this information is remarkably similar to the expression I receive when I mention Sections 3 and 9 are my favorite sections of Safety Data Sheets. I mean really, who doesn’t have a favorite Safety Data Sheet section?
Interestingly, this shipping section of the regulations is often overlooked by facilities receiving hazardous materials (raw materials) or generating hazardous waste. In 2019, more than 34.9 million tons of hazardous waste – equal to more than 69 billion pounds – was produced by large quantity generators (entities that create more than 2,200 pounds of hazardous waste per month). Moreover, these 34.9 million tons are produced by only 23,700 active large quantity hazardous waste generators.
Hazardous materials shipping regulations include the shipment of hazardous materials and/or hazardous wastes and encompass a behemoth set of complex policies and specialized topics subject to regulatory scrutiny. It’s rare a week passes without the media relating a story of improper transportation practices (i.e., air, water, and/or public roadways) that resulted in a disaster. The Federal Motor Carrier Safety Administration’s 2022 inspections noted the following top five violations for hazardous materials transportation.
Violations like these are avoidable as they should be covered in all hazardous material training. Compliant hazardous materials training addresses the three key aspects of hazardous materials safety: general awareness, function-specific training, and safety/security.
General awareness training for hazardous materials employees (hazardous waste or materials) requires the employee demonstrate an understanding of the employer’s (generating company’s) hazardous materials program.
Each hazmat employee shall 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.
The HMR’s function-specific and safety/security sections also apply to the specific job functions an employee performs and address the measures established to protect the employee from the risks associated with any hazardous materials they may be exposed in the workplace or during transportation. This required training applies to any company where hazardous materials, including hazardous waste, are received and/or shipped and impacts workers with duties such as packaging, marking and labeling, preparing/signing shipping papers, bulk loading or unloading, non-bulk loading or unloading, and/or hazardous waste manifesting. Depending on the course, these trainings vary in duration and level of expertise, as well as certification expirations that range from one to three years.
The effectiveness of HMR training is often noticeable as employees tend to quickly gain and demonstrate an understanding of the materials/wastes being shipped and received, the company’s policies, and their role in following the policies. Likewise, identifying the hazards associated with the materials and explaining the associated risks have a similarly profound effect. Not only does training strengthen the workforce by increasing the employees’ knowledge, but it also empowers skilled employees with responsibility and reduces the need for constant supervision and potential for fines resulting from violations.
Not sure if your company needs this training or if you have expired/outdated hazardous material shipment training? RETTEW offers a variety of courses and services to ensure organizations and businesses are prepared for hazardous materials management, including Resource Conservation and Recovery Act training; HAZWOPER 40-, 24-, and 8-hour; and various industry-specific programs.
Janel Simmers, Health, Safety, and Environment Team Lead
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