DOT

Implement the New DOT HazMat Rule

Wednesday, September 1st, 2010

Starting on October 1, 2010 the Department of Transportation will begin enforcing a revised Hazardous Materials transportation rule. This rule amends the Hazardous Materials Regulations to clarify requirements for using a third-party 24 hour emergency number.

KPA recommends you take both of the steps below to ensure your materials are easily identified in case of an accident. However, to be in compliance you should ensure at least one of the following is listed in close proximity to the 24 hour emergency number:

  1. Your facility name is clearly identified on the shipping papers.
  2. Your 24 hour emergency number provider account number is printed on the shipping papers.

New DOT HazMat Rule Goes into Effect October 1

Saturday, August 21st, 2010

Rule Summary

Starting on October 1, 2010 the Department of Transportation will begin enforcing a revised Hazardous Materials transportation rule. This rule amends the Hazardous Materials Regulations to clarify requirements for using a third-party 24 hour emergency number. In order for the emergency response operator to be able to link the materials you are shipping to your MSDSs and other emergency response information, the DOT is requiring that identifying information for your facility is listed on the shipping papers.

What you need to do

For most facilities, compliance with the new rule will be fairly straight forward. KPA recommends you take both of the steps below to ensure your materials are easily identified in case of an accident. However, to be in compliance you should ensure at least one of the following is listed in close proximity to the 24 hour emergency number:

  1. Your facility name is clearly identified on the shipping papers.
  2. Your 24 hour emergency number provider account number is printed on the shipping papers.

For example, to ensure the highest level of compliance, if your facility name is not listed elsewhere, you should list the following in the description section of the shipping paper:

Your Facility Name, 24 hour number, Acct#

If you have additional questions on this regulatory change or DOT hazmat regulations in general, talk with your current DOT hazmat provider to understand the upcoming changes in regulation.

For additional information, here is an electronic version of the 2008 Emergency Response Guidebook.

By Peter Zaidel and Wendy Hudson

Who needs DOT training?

Thursday, November 19th, 2009

Sounds like a simple question and you would expect a simple answer, doesn’t it? Yet, the reality is that many employees and employers alike don’t know the answer. Or worse, because they cannot readily find the answer, they assume they don’t need it. Unfortunately, in many cases they are required by DOT to have training.

Let’s review a few definitions and requirements.

Question: what defines a “hazmat employee”?

Answer: a hazmat employee is a person who is employed by a hazmat employer and who in the course of employment directly affects hazardous materials transportation safety. This term includes an individual, including a self-employed individual, employed by a hazmat employer who, in the course of employment: (1) Loads, unloads, or handles hazardous materials; (2) Manufactures, tests, reconditions, or repairs, modifies, marks, or otherwise represents containers, drums, or packages as qualified for use in the transportation of hazardous materials; (3) Prepares hazardous materials for transportation; (4) Is responsible for safety of transporting hazardous materials; or (5) Operates a vehicle used to transport hazardous materials.

Question: who needs DOT hazmat training?

Answer: all hazmat employees require training including the following: (1) General awareness/familiarization training, and (2) Function-specific training.

Question: when and how often do I need training?

Answer: Initial training by a new hazmat employee, or a hazmat employee who changes job functions must be completed within 90 days after employment or a change in job function. Recurring training is required at least once every three years.

Check out the DOT regulations for the 49 CFR, Part 172, Subpart H regulations or the website of the Federal Motor Carrier Safety Administration for a less formal and more readable explanation.