HAZMAT SHIPPING TRAINING

Anyone who performs the following pre-transportation functions of shipping hazardous materials needs to have training:

• Transports hazmat in commerce or causes hazmat to be transported in commerce.
• Represents, marks, certifies (signs off on manifests or paperwork), sells, offers, accepts, reconditions, tests, repairs or modifies packagings as qualified for use in the transportation of hazmat.
• Signs off on hazardous waste manifests, even if the hazardous waste disposal company does all the manifesting, labeling and placarding for you.
• Loads, unloads, or handles hazmat.
• Tests, reconditions, repairs, modifies, marks or otherwise represents packagings as qualified for use in the transportation of hazmat (i.e., makes packages, labels them or determines they are proper for shipping hazmat in).
• Prepares hazmat for transportation (anyone packaging the materials or filling out/typing paperwork, such as administrative assistants who help).
• Writes dangerous goods stowage/unloading plans or enforces hazmat compliance laws.
• Forwards freight and accepts/transfers/handles/unloads cargo, mail or passengers from planes.
• Screens baggage, cargo or mail.
• Is responsible for safety of transporting hazmat or operating a vehicle used to transport hazmat.
• Packages hazmat for, loads, or arranges for hazmat shipments into cargo containers, even if a freight forwarder is actually doing the shipping.

You cannot ship any hazardous materials until you have had refresher training.  DOT and IMDG refreshers are required every 3 years.  IATA refreshers are required every 2 years.  With these refreshers, dates do matter so make sure your refresher training is completed on or before the anniversary date on your last certification.

DOT (49 CFR) is for shipments of hazardous materials which will go by ground methods, that is, by truck or train.  IATA is for hazmat shipments which will be sent by air, such as overnight packages or shipments to other countries.  IMDG is for shipping by vessel, or ship. Besides other countries, this would include shipping materials to Hawaii, Alaska and Puerto Rico where the packages were not going by airplane.

Please note, if you have someone else ship your hazardous materials for you, such as a hazardous waste disposal company who picks up your hazardous waste drums, or having a freight forwarder load shipping containers for you, you are still the official shipper of record and your personnel still need to be trained as if they were sending it themselves.  Your employees need to be able to ensure the company transporting your materials are doing it correctly.

Know what your company is shipping and be on the alert for hazardous materials because many customers have not realized they were shipping hazardous materials when they actually were.  Items such as patch and repair kits that have glues or paints are considered hazmat, as well as fire extinguishers, items with lithium ion batteries in them and engines with trace amounts of fuel left in them can be considered hazardous materials.

Per 14 CFR 145, or FAR Part 145, if an FAA-certified repair station performs or directly supervises job functions involving hazmat transported on board an aircraft, whether the hazmat is owned or used by them or their client, the repair station is required to have a hazmat policy and conduct training per 49 CFR. The shippers, i.e., those who are actually doing the packaging, signing manifests and filling out paperwork, need to take the full function specific training class. Everyone else who “touches” it, such as a person at the dock who unloads a truck, someone who works on an instrument which qualifies as having hazardous materials or someone who is responsible for purchasing packages, is required to have awareness training per 49 CFR.  iSi provides Part 145 training as an onsite or custom course only.

Yes, if it’s within 3 months of the due date. Per IATA regulations, refresher training must take place within 24 months of previous training.  If you complete your refresher early, within 3 months before expiration, your new expiration will be 24 months from your original, and later, expiration date.  Remember that IATA training is required upon hire or transfer of duties.