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COUNTERMEASURE
Objective:
To improve hazardous materials transportation safety through the
comprehensive training of Hazmat employees.
Description:
A high percentage of hazardous materials incidents are caused by human
error and lack of proper training. The number of such incidents may be
greatly reduced by the thorough training of Hazmat employees.
Questions
for Management:
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What
supervisory personnel are responsible for Hazmat shipments and are
these people properly trained?
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Are all
Hazmat employees trained to handle hazardous materials incidents?
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Are Hazmat
employees given emergency response training?
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Are Hazmat
employees aware of correct procedures for notifying authorities of
an incident?
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Can Hazmat
employees properly use the Emergency Response Guidebook?
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Are Hazmat
employees qualified to perform adequate inspections of vehicle and
cargo?
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Are HM
employees trained to determine compatibility of mixed
loads/suitability of vehicles?
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Do Hazmat
employees have adequate knowledge of correct equipment usage ?
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Are drivers
trained in state law, federal regs and company policy regarding
safe driving?
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Are drivers
aware of the hazards of railway crossings?
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Are drivers
aware of regs & conditions which require that drivers remain
with their vehicles?
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Do drivers
practice defensive driving techniques?
Tips for
Management:
-
Introduce
refresher training for Hazmat employees.
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Initiate a
recognition program for well-trained Hazmat employees.
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Training
programs should include cargo-specific training.
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Introduce
specialized training for tank truck drivers.
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Arrange for
drivers to gain non-Hazmat hauling experience before hauling HM.
Tips for
Hazmat Employees:
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Do not take
shortcuts or vary from established hazardous materials handling
procedures.
-
Practice safe
driving techniques at all times.
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Prior to
trip, get adequate rest and nourishment.
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Maintain your
high driving alertness by taking rest stops, avoiding caffeine and
reducing cab temperature.
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Reduce
vehicle speed, especially on ramps and curves.
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Many
accidents occur while crossing train tracks; do not shift gears
when crossing train tracks.
References:
49 CFR Parts: 172 Subpart H; 177.848; 383 Subpart G; 392; 397. A8, A9,
A10, B1, B2, B4, B11, B12, C2, C11, C12, G1, G3, G4, G6, G12, G13,
G14.
LOADING/UNLOADING
TRAINING T2
COUNTERMEASURE
Objective:
To reduce the frequency of Hazmat loading and unloading incidents by
training personnel in the correct procedures.
Description:
Many incidents involving hazardous materials occur during the loading
or unloading phases of transportation. Training in correct handling
procedures as well as educating personnel about the potential dangers
of hazardous materials may help reduce the frequency of these
occurrences.
Questions
for Management:
-
Are personnel
familiar with the properties and characteristics of the materials
they are handling?
-
Is training
available for personnel involved with loading and unloading
hazardous material?
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Are personnel
trained in grounding and bonding requirements and procedures?
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Are personnel
aware of correct compressed-gas cylinder pickup procedures?
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Are there
established procedures for switch loading?
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Are drivers
trained and encouraged to recognize packages which are not
authorized or packages that may be defective?
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Is a closed
cargo space used for all hazardous materials (unless fire and
water resistant)?
Tips for
Management:
-
Train
personnel in safe loading techniques and to be alert for pinch
points.
-
Train
personnel to turn off the truck engine during loading and
unloading whenever possible; if the engine is required for
pumping, it should be turned off while hoses are being connected
and disconnected.
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Personnel
involved in confined-space loading/unloading activities should be
trained in confined-space entry hazards.
Tips for
Hazmat Employees:
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Check safety
guide before loading or unloading begins.
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Remove
ignition keys prior to loading/unloading to avoid
"pull-away" incidents.
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Be careful
not to overfill or overload tanks.
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Be careful
when handling cylinders and packages of hazardous materials.
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Handle empty
drums with the same caution as full drums.
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Do not
overload closed cargo spaces; allow air to circulate.
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Close all
access flanges and valves before moving and allow adequate
relaxation time.
References:
49 CFR Parts: 172 Subpart H; 173.24; 173.29; 173.30; 392.9; 393
Subpart I. A11, C2, C11, C12, G1, G2, G4, B1, B5, T2.
CLASSIFICATION
TRAINING T3
COUNTERMEASURE
Objective:
To reduce the frequency and/or severity of hazardous materials
incidents by training Hazmat employees to properly classify hazardous
materials.
Description:
The shipping process begins with a desire or need to ship a material.
Subsequent shipping activities, such as packaging, labeling, marking,
handling, placarding, etc., are affected by the characteristics and
potential hazards of the material being offered. Training Hazmat
employees in proper classification procedures will promote accurate
classification and safety throughout the hazardous materials
transportation process.
Questions
for Management:
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Are all
Hazmat employees involved in hazardous materials classification
trained properly?
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Are updated
reference materials regularly provided to Hazmat employees?
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Are refresher
courses offered to Hazmat employees?
Tips for
Management:
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Participate
in training which is appropriate.
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Register
Hazmat employees in training courses which include compulsory
evaluations.
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Encourage and
support Hazmat employee training by recognizing successful
completion of training courses.
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Encourage
Hazmat employees to share training materials and tips learned at
training courses.
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Encourage
Hazmat employees to help develop each others' skills.
Tips for
Hazmat Employees:
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Become
familiar with types of classifications for hazardous materials.
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Inform
management if/when you feel that additional training is needed.
References:
49 CFR Parts: 172 Subpart H. C11, G3, G12, G13, B8.
PLACARDING
TRAINING T4
COUNTERMEASURE
Objective:
To communicate the potential hazards of transported materials by
training the driver and loading/unloading personnel in correct
hazardous materials placarding.
Description:
In the event of an emergency situation, it is critical that the
primary hazards associated with a shipment be communicated to
emergency response personnel and to other people in the immediate
area. Placards enable the hazards of a cargo to be identified from a
distance. Personnel who are properly trained may detect placarding
procedures which do not comply with regulations and thereby avoid
dangerous and costly errors at an emergency scene.
Questions
for Management:
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Are Hazmat
employees aware of when to placard vehicles?
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Are Hazmat
employees trained and able to properly placard vehicles when
necessary?
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Does the
schedule permit the proper placarding of vehicles by Hazmat
employees?
Tips for
Management:
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Train
personnel in the importance of placarding.
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Encourage use
of specific placards when necessary.
Tips for
Hazmat Employees:
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Know what to
do with the hazardous materials cargo in case of an emergency
situation.
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Become
familiar with the properties of your hazardous materials cargo;
placards provide only general information, particularly with
respect to mixed loads.
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Use
material-specific placards whenever possible; for example, avoid
using the general placard for "flammable liquid, not
otherwise specified" if a more specific placard is
appropriate.
References:
49 CFR Parts: 172 Subpart F; 172.600; 172 Subpart H; 173.22;
177.816;397. B12, C12, G6, G12, G13, B8, B9.
SHIPPING
PAPERS TRAINING T5
COUNTERMEASURE
Objective:
To ensure correct identification of shipped hazardous materials by
training employees to interpret shipping papers correctly and to
recognize discrepancies, omissions and errors in the documents.
Description:
Shipping papers are the most important source of information available
to identify the hazardous materials involved in an incident. The first
emergency response is often determined by the information contained in
the shipping papers. Training employees to recognize irregularities
and errors in shipping papers is necessary to help ensure that
shipping papers can properly inform emergency responders and everyone
else.
Questions
for Management:
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Are employees
trained in the importance and use of shipping papers?
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Are employees
able to recognize discrepancies between the materials loaded on a
truck and the items shown on the shipping papers?
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Are drivers
aware of where shipping papers should be carried & how they
are to be handled?
Tips for
Management:
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Perform
regular audits of shipping papers and cargo to ensure that both
company personnel and clients are properly completing papers.
Tips for
Hazmat Employees:
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Review
shipping papers carefully before pulling away.
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Become
familiar with the properties of your cargo since shipping papers
do not provide complete information.
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Be familiar
with the proper emergency procedures and the people to contact in
case of an emergency.
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Know what to
do with the cargo in case of an emergency situation.
References:
49 CFR Parts: 172 Subpart C; 172.704; 177.817; 397.19. A8, A11, B12,
G3, G12, G13, B8, B9.
LABELING
TRAINING T6
COUNTERMEASURE
Objective:
To promote accurate identification and recognition of the potential
dangers of hazardous materials packages by training Hazmat employees
in the correct labeling procedures.
Description:
The type of material shipped determines, among other things, handling
procedures, placards and emergency response. Correct labeling is
important for identifying the hazards of a material both on a routine
basis as well as in emergency situations. Labels are also used to
check shipping papers and to assist loading and unloading personnel to
safely distribute mixed loads.
Questions
for Management:
-
Are personnel
trained in interpreting labels?
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Are personnel
trained in checking labels against shipping papers and placards?
Tips for
Management:
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Emphasize the
value of Hazmat labels both in routine and in emergency
situations.
Tips for
Hazmat Employees:
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Know what to
do with the cargo in case of an emergency situation.
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Do not rely
on package labels in emergency situations, but rather refer to
shipping papers and safety literature to become familiar with the
properties of your cargo since package labels provide only limited
information.
References:
49 CFR Parts: 172 Subpart E; 172.704; 177.817. B12, C11, G12, G13, B8,
B9.
MARKING
TRAINING T7
COUNTERMEASURE
Objective:
To promote correct package marking and to improve the conspicuity of
hazardous materials cargo by training Hazmat employees in correct
package marking procedures.
Description:
A package containing hazardous materials must be marked with
either the consignee's or the consignor's name and mailing address as
well as proper shipping name, identification number and certain
warnings if applicable. Package markings contain information which may
be important in certain emergency situations, such as when the package
is separated from the vehicle. In addition, the information provided
in package markings should agree with that given in shipping papers.
Questions
for Management:
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Are personnel
trained in checking package markings against shipping papers and
placards?
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Are personnel
trained in interpreting package markings?
Tips for
Management:
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Educate
personnel about the value and utility of package marking in
routine and emergency situations
.
Tips for
Hazmat Employees:
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Familiarize
yourself with the properties of the cargo because package markings
provide only limited information.
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Refer to
shipping papers and safety literature for appropriate precautions
and procedures.
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Know what to
do with the cargo in case of an emergency situation.
References:
49 CFR Parts: 172.300; 172.326; 172.328; 172.704; 177.826. A11, B12,
C11, G3, G12, B8, B9.
PACKAGING
TRAINING T8
COUNTERMEASURE
Objective:
To reduce the frequency and/or severity of hazardous materials
incidents by adequately training Hazmat employees in proper packaging
procedures.
Description:
Adequate packaging is a critical activity in the hazardous materials
transportation process. Packaging is the first line of defense for
containing hazardous materials in the event of an accident, yet
inadequate packaging is commonly cited as a factor which contributed
to a hazardous materials incident. Adequately training Hazmat
employees in proper packaging may reduce the number of shipments prone
to package failure.
Questions
for Management:
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Does company
philosophy encourage employees to put in extra effort to "do
it right?"
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Has
management committed sufficient resources to Hazmat employee
training?
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Is management
familiar with applicable regulatory guidelines regarding Hazmat
employee training?
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Are Hazmat
employees adequately trained?
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Are Hazmat
employees encouraged or required to participate in training
programs?
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Are Hazmat
employees who successfully complete training courses publicly
recognized?
Tips for
Management:
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Register
Hazmat employees in approved training courses which include
competency evaluations.
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Provide
opportunities for Hazmat employees to take refresher courses.
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Encourage
Hazmat employees to share training materials and tips learned in
training courses.
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Encourage
Hazmat employees to help develop each others' skills.
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Periodically
monitor packaging operations for compliance with company policy
and applicable regulations.
Tips for
Hazmat Employees:
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Become
familiar with appropriate packaging for various hazardous
materials.
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Inform
management if/when you feel that additional training is needed.
References:
49 CFR Parts: 172 Subpart H; 173; 178; 180. A3, C11, C12, G3, G9.
EMERGENCY
RESPONSE TRAINING T9
COUNTERMEASURE
Objective:
To prevent a hazardous materials incident from becoming more serious
by training personnel to respond quickly and appropriately.
Description:
It is crucial that the response to a hazardous materials incident be
rapid and proper. An improper emergency response can result in an
incident far worse than the initial incident. Properly training
personnel to respond to incidents may reduce the number of Hazmat
incidents that are aggravated by improper first responses.
Questions
for Management:
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Are personnel
trained in correct emergency response procedures?
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Are there
pre-planned emergency responses for given situations?
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Are personnel
evaluated regularly for proper emergency response procedures?
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Are Hazmat
employees encouraged to learn such emergency responses?
Tips for
Management:
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Coordinate
emergency response efforts with those of local authorities.
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Establish
company emergency response teams.
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Use exercises
and drills as emergency response training aids.
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Train
employees in the proper use of personal protection equipment.
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Train
employees in decontamination and disposal procedures.
Tips for
Hazmat Employees:
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As a general
rule, keep out of line with the ends of a tank undergoing fire
exposure.
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Do not
perform an aggressive response unless appropriate procedures have
been established, correct equipment is available and the material
properties are known.
References:
49 CFR Parts: 172 Subpart G; 172 Subpart H. B12, G1, G10.
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