9.3 DOT Requirements
A. A HAZMAT employer must ensure that each of its HAZMAT employees is trained in
accordance with the requirements of 49 CFR, Subpart H, of Part 172. A HAZMAT employee
who performs any function regulated by the hazardous materials regulations (HMR) may not
perform that function unless he or she has received training as described in Subpart H of Part
172. Each HAZMAT employer has a duty to comply with the applicable requirements of the
hazardous materials regulations and to thoroughly instruct each HAZMAT employee on how to
comply with the regulations.
B. The required training may be provided by the HAZMAT employer or other public or private
sources. Every HAZMAT employee must receive both initial and recurrent training that
includes:
* General awareness/familiarization training
* Function-specific training
* Safety training
* Testing
C. Each HAZMAT employer is responsible for compliance with the DOT regulations for
shippers, transporters, and manufacturers, regardless of whether the training required by the DOT
HAZMAT training regulations has been completed. This means that compliance with the
substantive rules cannot be put off until training is completed, and that providing training does
not excuse violations of the rules. The employer must provide both initial and recurrent training
as specified in 49 CFR subpart H.
D. Driver Training. In addition to other training requirements of the hazardous materials
regulations, 49 CFR 177.816 requires that no carrier may transport, or cause to be transported, a
hazardous material unless each HAZMAT employee who will operate a motor vehicle has been
trained in the applicable requirements of 49 CFR parts 390-397, and the procedures necessary for
the safe operation of that motor vehicle.
9.4 EPA Requirements. Title 40 CFR, section 264.16, requires that employees assigned duties
at a hazardous waste storage facility successfully complete a program of classroom instruction or
on-the-job training that teaches them to perform their duties in a way that ensures the facility's
compliance with the requirements of Title 40 CFR, part 264. This program must be directed by a
person trained in hazardous waste management procedures (including contingency plan
implementation) relevant to the positions in which they are employed. As a minimum, the
training program must ensure that facility employees are able to respond effectively to
emergencies by familiarizing them with emergency procedures, emergency equipment, and
emergency systems.
9.5 OSHA Requirements
A. Occupational Safety and Health (General).
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