The Department of Transportation (DOT) regulates the transport of hazardous material via highway, air, railroad, and vessel. A hazmat employee, as defined in 49 CFR 171.8, is an employee that directly affects hazardous materials transportation safety. For Life Science companies, this typically means individuals that package DOT-regulated materials for shipment or offer hazardous chemical waste or regulated biological waste for transport for off-site disposal. DOT-regulated materials include the obvious flammables, toxics, corrosives materials, but also includes dry ice as a Class 9 regulated substance. Any employee signing a waste manifest, a dangerous goods declaration, or any document with a shipper’s declaration stating that the materials are in conformance with DOT regulations, must be trained prior to signing the declaration.
In addition, it is not sufficient to simply take DOT training. Once training is completed, the company must certify each trained employee as a hazmat employee of their company. DOT training is valid for three years, so hazmat employee need to attend refresher training and be recertified every three years. Federal Aviation Administration (FAA) and DOT regulators look for complete training records during inspections and can impose steep fines for non-compliance.
Safety Partners offers an on-line DOT training course tailored to Life Science companies that ship hazardous chemical and biological waste, and non-regulated materials on dry ice. The benefits of this training include reasonable course cost, on-line access, and a tailored presentation so time is not spent training on parts of the regulation that are not applicable. If a company is consistently shipping DOT-regulated materials, a comprehensive full-day course is needed.