1.01 This Policy and Procedures Letter details Ohio University's compliance with the Hazardous Materials Employee training requirements of CFR49 Parts 171-177 as stated in Docket No. HM-126F, the Hazardous Materials Transportation Act (HMTA), and the Hazardous Materials Transportation Uniform Safety Act of 1990 (HMTUSA).
1.02 "Hazmat Employers" are required to train their "Hazmat Employees" regarding the safe transportation of hazardous materials. The acts require coordination of rules to avoid conflicts with other federal agency rules
a. Hazmat Employer -- uses one or more employees to:
- Transport hazardous materials in commerce,
- Cause hazardous materials to be transported or shipped in commerce, or
- Represent, mark, certify, sell, offer, recondition, test, repair, or modify containers, drums, or packages as qualified for use in the transportation of hazardous materials.
b. Hazmat Employee -- employed by a Hazmat Employer in a manner that directly affects hazardous materials transportation safety. Activities of a Hazmat employee include:
- Loads, unloads, or handles hazardous materials,
- Tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packaging as qualified for use in the transportation of hazardous materials,
- Prepares hazardous materials for transportation,
- Responsible for safety of transporting hazardous materials, or
- Operates a vehicle used to transport hazardous materials.
1.04 Examples of Hazmat Employees requiring training:
a. A person determining whether a material is a hazardous material,
b. A person designing, producing, and/or selling a packing for hazardous materials,
c. A person determining proper packaging for a hazardous material,
d. A person who puts the hazardous material in the package,
e. A person who marks and labels the package,
f. A person who fills out shipping papers,
g. A person who loads or unloads the hazardous material,
h. A person who moves the packaging in a warehouse during the course of transportation,
i. A person who operates a vehicle transporting the materials.
1.05 Training used to satisfy other federal hazardous material safety programs may be used in part or in full to satisfy these requirements.
a. General Awareness/Familiarization Training
b. Function-specific Training
c. Safety Training
d. Driver Training
e. Testing and Certification
f. Training Record Keeping
Ohio University's Training Program
2.01 General Awareness and Safety Training will be given to each employee in conjunction with hazard communication training.
2.02 Driver Training will be provided by a computer interactive program available on the Internet. This is for drivers that will be transporting outside the city of Athens vicinity.2.03 The Hazardous Material Manager at Environmental Health and Safety (EHS) will provide assistance and materials for the training in 3.01 and 3.02.
2.04 The Hazardous Materials Manager will be responsible for determining the hazard level and overseeing the shipping process including packaging, marking, labeling, documenting, and shipping all hazardous materials.
2.05 The Hazardous Materials Manager is to be contacted immediately when potentially hazardous materials are to be shipped.
2.06 Training is required within 90 days of hiring and at least every three years thereafter.
2.07 OU must certify that all Hazmat Employees have been trained and tested. A record of this training must be created and maintained for each Hazmat Employee for the length of employment plus 90 days.
3.01 Department heads will be responsible for:
a. Giving General Awareness and Safety Training to all employees within the above time standards,
b. Requiring Driver Training for employees transporting Hazardous Materials in commerce,
c. Reporting general and driver training times, dates, names, and test certification to EHS.
3.02 EHS will be responsible for assisting supervisors or department heads in necessary training and reporting requirements.
3.03 EHS will be responsible for OU record keeping for hazardous materials training.
For supporting University policy and procedure see Policy and Procedures
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