When you ship hazardous materials, are you in compliance? Here are seven steps to building a thorough program.
Get Employees Trained and Certified in 49 CFR
The safe handling and transport of hazardous materials begins with training. It is every Hazmat Employer’s responsibility to ensure its employees are trained and tested in accordance with the requirements of 49 CFR Part 172.704. A Hazmat Employer is defined as any company that engages, on a full-time or part-time or temporary basis, Hazmat Employees who ship or cause to be shipped hazardous materials, including those who:
- load, unload, or handle hazardous materials,
- prepare hazardous materials for transportation, and/or
- operate a vehicle used to transport hazardous materials.
A Hazmat Employee also includes any person who designs, manufactures, fabricates, inspects, marks, reconditions, maintains/repairs, or tests a package or packaging component that is represented as qualified for use in transporting hazardous materials.
There are five types of training that employees must complete:
- General Awareness/Familiarization Training – overview of the regulations; enables the employee to recognize and identify hazardous materials consistent with the hazardous communication standards of the employer.
- Function-Specific Training – customized lessons specifically applicable to the functions the employee performs.
- Safety Training – emergency-response and self-protection measures.
- Security Awareness Training – awareness of security risks associated with hazardous material transportation; covers ways to enhance transportation security and recognize and respond to possible security threats.
- In-Depth Security Training – more detailed training regarding the company’s security objectives and procedures, employee responsibilities, and actions to take in the event of a security breach.
Initial training should be completed within 90 days after beginning employment or a change in job function. Recurrent training must be completed at least once every three years. All training records must be kept by the employer, including current and preceding training, as long as that employee is employed by the company and for 90 days thereafter.
Get Material Safety Data Sheets on All Materials
Material Safety Data Sheets (MSDS) clearly outline the nature of any hazardous materials. MSDS will help you classify and communicate any hazard information properly. They will assist you with the Proper Shipping Name, Class of Hazard, and the UN Identification Number that can be cross-referenced to the Hazardous Materials Table in 49 CFR Part 172. This table indicates the information you will need to move forward in preparing your shipment.
The MSDS should be up-to-date and stored in a central location.
Determine Necessary Packaging and Labels
Selecting the mode of transport (air, ground, rail, and sea) is the next step. This can influence the packaging, the quantity per package, markings and labeling required, documentation, and certifications. Again, the Hazardous Materials Table, along with other sections in the 49 CFR Part 172, will provide the necessary information.
The proper package selection will include consideration of inner-packaging volume, number of inner packagings per package, cushioning and absorbents, closure and reinforcement, as well as other factors.
Ensure the Package in Which You Will Ship Has Been Tested and Certified
After determining what package you must use, you must source this exact package. Whether working with outside suppliers or your own internal packaging team, you will need to check that the proper package is supplied, is correctly marked, and is fi t for use.
Use the Package Correctly When Shipping
You must prepare the package in the same manner in which it was tested and certified. The package supplier is required to provide detailed assembly and closing instructions, and the package user needs to keep these instructions on file. The closing instructions should include closing torque requirements for all closure types as well as full assembly instructions. Follow these instructions perfectly and complete all necessary paperwork.
Declare the Package with the Shipping Carrier
It is the shipper’s responsibility to declare the package as a hazardous material, or dangerous good, with the carrier. Many dangerous goods cannot be shipped with other products, so proper declarations allow the carrier to segregate freight correctly.
Retain All Shipping Records
Shipping records, paper or electronic, must be retained on every shipment for two years after the material is accepted by the initial carrier. For hazardous waste, the records must be retained for three years.