How to Establish a Hazmat Program

By Diane M. Calabrese / Published May 2019

R

adioactive? No? Good.

Perhaps one fewer government entity—in this case, the Nuclear Regulatory Commission—will take an interest in the hazard potential of the material. Do count, though, the Environmental Protection Agency, Occupational Safety and Health Administration, and Department of Transportation. For our industry, they usually are the list, but it could be longer. Don’t completely exclude the NRC, which regulates both radioactive material and byproducts of radioactive material.

Does your company need to establish a hazmat program? The good news is there’s plenty of help available. The bad news is there’s plenty of help available, so much that it can be as difficult to sort through as a DIY project. Seek help.

It can get complicated. So, let’s begin with the most straightforward ways to remain in compliance with handling or working with or around hazardous materials.

“A major function of the trade association is to update members each year on hazmat requirements,” says Robert M. Hinderliter, an environmental consultant with decades of experience in our industry, who is based in Burleson, TX. He adds that such readily available assistance, and especially updates, is one big reason for belonging to a professional organization. Another big reason, he explains, is the ties formed with industry colleagues.

It requires a methodical approach to meet all hazmat regulations that apply. Contractors, for instance, must know what the materials of their trade are, explains Hinderliter. Then, they can be sure that the training to which they commit matches their requirements.

The intricacies of hazmat cannot be overstated. Truckers and manufacturers have additional requirements. Dealers may assist customers by providing information, but the customer will likely still need hazmat training. (It’s possible there are contractors who use no hazardous materials in cleaning. But, they may be working in areas where they do need training—and certification—because of the hazardous materials on the site where they are cleaning, such as a hospital or a manufacturing plant.)

Fines for violations of hazmat rules can be staggering. Compliance is a must. An owner never knows when an inspection might occur.

“I had three un-notified inspections in 30 years,” says Hinderliter. “I passed every one of them.”

Consider it Done

Anyone who still entertains the thought that hazmat training is for the other person need only enter “hazmat courses” (2,090,000 results returned) or “hazmat trainer” (1,460,000 results returned) through an internet search engine. Duplicates, sure, but the point is made.

For those setting up their first hazmat training program, it makes sense to start with the one entity that has a universal interest in eliminating hazards in the workplace. That entity is OSHA.

“OSHA.gov offers the best source of information for contractors, distributors, and manufacturers trying to determine whether they are required to have a hazmat program,” says Linda Chambers, brand and sales manager, GCE/Soap Warehouse Brand in Norcross, GA. “They have everything you need to learn about who and what is required for safety and hazmat and what you have to cover for training.”

Chambers stresses that the OSHA information only begins the process. “After that they need to check with their state and local government agencies as to what other regulations they might have to conform to above the federal ones,” she explains. 

Training and certification take time and cost money. But there are many options—as the internet search results illustrate. 

“If you do not have the time but have the financial resources, then it can make sense to hire a firm like Lion Technology Inc. to train all your employees,” says Chambers. “Or, if you have a staff member who is your safety director but you want to pay for some resources, companies like Vivid Learning Systems can help with employee training resources.”

There are different requirements for different categories of employees. Not all employees must be certified. With that in mind, there are some ways to scale back the total cost of training.

“I go the cheapest route, which is to read and watch videos in order to learn how to set up normal safety training to train our staff,” explains Chambers. “You only have to follow the training guidelines given by OSHA to give safety training—you do not have to pay for it. But certain employees, like CDL drivers and your hazmat shipping staff, if you have them, need certified training every three years that you have to pay a company to receive. I get mine through Infotrac every three years.”

There is a risk for companies who think they fall outside the purview of hazmat regulations. And, again, checking OSHA requirements (as a start) and belonging to and seeking advice from a professional organization are good ways to avoid the mistake of thinking a company is exempt.

“A small cleaning company that buys its cleaning products from big box or membership club stores may think that just because they are buying consumer branded products that they do not have to worry about OSHA, getting SDSs, or having a hazmat program for their employees,” says Chambers. “They do not realize that as soon as they have employees who are using these chemicals daily in performing their jobs, they have to follow OSHA and hazmat guidelines when using them and must train their employees.” 

Just do it—the hazmat training—applies here.

Fundamentals

Carcinogenic, toxic, corrosive, combustible, compressed, explosive, or unstable (reactive), or capable of releasing dust, gases, fumes, vapors, or smoke in the course of normal handling? Well, then, it’s a hazardous material. (And that is simply an abridged list.)

Just assume every employee who comes into contact with the chemicals being used on the plant floor, being sold, or being used on jobsites requires OSHA hazmat training. What about training in OSHA HAZWOPER (hazardous waste operations and emergency response)? It’s a tricky call.

A contractor headed to a jobsite while carrying chemicals that are classified as hazardous material will only need HAZWOPER training if he or she plans to leap into action and assist emergency responders in the event of a vehicle accident and spill. What a contractor traveling from one job to another must have, however, is training in hazard communication.

Employees must have access to safety data sheets when they are in their work area. If power washing contractor employees have hazardous chemicals on their vehicles, they must carry with them the SDSs (consistent with GHS, the U.N. Globally Harmonized System of Classification and Labeling of Chemicals).

Because most employees must have training, but not all employees must be certified in hazmat handling, some employers develop programs of their own. Programs developed in house can be very good because the employer can tailor it to potential hazmat issues at the company.

We suggest turning to the “Guide to Developing a Hazmat Training Program” at www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/training/hazmat/6586/guide-developing-hazmat-training-program.pdf. This is 30 pages of clarity and excellent help published by the Pipeline and Hazardous Materials Safety Administration (PHMSA) at the DOT. Although the Guide focuses on the strict rules for transporting hazardous materials, it is useful to all who deal with hazmat.

The remainder of this section highlights some information in the Guide:

Lack of knowledge and awareness are big contributors to human error regarding hazmat. Employees must be trained to know how to handle hazmat safely, including how to respond if there is an incident.

A hazmat program that is effective is part of a strong safety culture. The culture of safety is so strong employees have a deep appreciation of why compliance and safety are necessary.

There are five levels of required training for those following DOT regulations. The last two concern security awareness and in-depth security
training. The first three—general awareness/familiarization training, function-specific training, and safety training—apply to any industrial sector.

After a company determines which employees require hazmat training and the type of training they require, the content, type, and method of delivery are the next considerations. The superb advice provided on content—how to target it to the audience and make certain it is received—would be good guidance to anyone aspiring to be an excellent teacher.

Two pages (pages 13 and 14) tabulate the advantages of four training options—web-based, computer-based, classroom, and hands-on/mentor. If establishing a program, the side-by-side comparisons are a must read.

Finally, sections on how to choose a safety coordinator, how to develop a recordkeeping system that is consistent and accessible, and how to develop checklists for training policy and training program (topics) are invaluable.

Not Hazardous and Radioactive

In sufficient quantities just about any substance can become hazardous. Think water and ice, although neither fits the regulatory definition of a hazardous material.

Americium-241 does fit the definition of a hazardous material. It is radioactive. But because it is the functional element (isotope) in ionization smoke detectors, its benefit is deemed to outweigh its exceedingly low risk. (Disposal of detectors in regular trash is permitted in many places.)

Extracting the benefit while minimizing the risk is the first priority when using a hazardous material. Hazmat training keeps the focus on the benefits of hazardous materials because no one becomes distracted by preventable incidents.