If you are involved with the operation of an organization in which the workers face the potential for some sort of exposure to hazardous materials, proper training for them is vital. In addition, there are regulatory requirements from the various agencies that require training. Organizations like the Advanced Hazmat Life Support (AHLS) team can provide training to companies who do not have the internal resources to conduct it in house. CBRNE training as well as other training required by OSHA, EPA or DOT can be conducted. With the rise of terrorist threats in recent years, this training has never been more important.
OSHA requires training for the protection of employees who will be working with products that could pose a hazard, typically referring to such products as “hazardous chemicals”. The regulation that affects the most employees is the hazard communication standard. This is commonly referred to as the worker right-to-know rule. It requires a written plan that describes how employees are to be trained, how containers will be labeled and how Safety Data Sheets (SDS) will be maintained.
In its HAZWOPER standard, OSHA borrows some terminology from the EPA in laying out training requirements for employees who will be responding to the releases of hazardous waste or other emergency operations.
While OSHA requires training primarily to protect the worker, the Environmental Protection Agency (EPA) requires it to protect the environment, which may also include the health of the population in general. There are a number of regulations that apply, depending on the activity. For example, companies that generate waste that meets the EPA’s definition of hazardous will be impacted by the Hazardous Waste Rules. Companies that use or store certain amounts of oil will be impacted by the requirements to have an oil spill contingency plan. Other EPA requirements dictate that companies file annual or biennial reports if their activity exceeds given thresholds.
The Department of Transportation requires training for individuals who will in some way be a part of the transportation process of hazardous materials. This requirement is not limited to truck drivers or employees of transportation companies. Businesses that ship or receive materials that meet the DOT’s definition of hazardous must ensure their employees who load, unload or offer these materials for shipment are properly trained.
While it is sometimes possible to combine training to meet the requirements of all the regulatory agencies, care must be exercised in order to make sure each requirement is addressed. This requires a careful examination of each of the applicable rules. Each has its own requirement for the way the training is delivered, testing is conducted and records are maintained.