Department of Transportation (DOT) – HM126F Training

Federal Department of Transportation regulation 49CFR § 172.704 HM126F requires that employers who are are involved in the following activities train employees:

• Transporting hazardous materials in commerce;
• Causing hazardous materials to be transported or shipped in commerce; or
• Representing, marking, certifying, selling, offering, reconditioning, testing, repairing, or modifying containers, drums, or packaging as qualified for use in the transportation of hazardous materials.

Note that this includes those who offer for shipment, as well as those who actually physically transport the waste. Facilities that have waste hauled from their site by an outside waste hauler are required to train employees in the HM126f training.

Employees who must be trained include those that, during the course of employment:

• Loads, unloads, or handles hazardous materials;
• Test, recondition, repair, modify, mark, or otherwise represent containers, drums or packaging as qualified for use in the transportation of hazardous materials;
• Prepare hazardous materials for transportation;
• Are responsible for safety of transportation;
• Are responsible for safety of transporting hazardous materials or
• Operate a vehicle used to transport hazardous materials.

This can include purchasing personnel, employees that label the shipping containers, waste handlers, and those employees that are signing the hazardous waste manifests.

Newly hired employees must be trained within 90 days of their employment. Retraining must be conducted every 3 years.

This training covers:

1. Overview of Hazardous Materials Transportation: Understanding the importance of transporting hazardous materials safely, the potential risks, and the regulatory framework.
2. Classification of Hazardous Materials: Identifying and classifying hazardous materials based on their physical and chemical properties, which determines how they should be handled and transported.
3. Hazard Communication: Proper labeling, marking, and placarding of hazardous materials to ensure that everyone involved in transportation is aware of the potential hazards.
4. Packaging Requirements: Learning about the specific packaging requirements for different types of hazardous materials to prevent leaks, spills, and reactions during transportation.
5. Shipping Papers: Understanding the documentation required for hazardous materials shipments, including how to accurately complete shipping papers (bills of lading) and emergency response information.
6. Loading and Unloading Procedures: Ensuring that hazardous materials are loaded, secured, and unloaded safely to prevent accidents and incidents during transportation.
7. Emergency Response: Being prepared for emergencies, including understanding the proper procedures to follow in case of accidents, spills, leaks, or other incidents involving hazardous materials.
8. Training Requirements: Understanding the specific training requirements for hazmat employees, including recurrent training, and ensuring compliance with DOT regulations.
9. Security Awareness: Recognizing the importance of security measures to prevent unauthorized access to hazardous materials shipments.
10. Recordkeeping: Maintaining accurate records of hazardous materials transportation activities, training, and incidents.