What hazmat training is required for office personnel and other staff who are not directly involved in handling or reviewing shipments consisting of dangerous goods (DG)/hazardous materials (HazMat)?
Do office personnel and clerks need to be hazmat trained?
Some people have questions about the training required for office personnel and other staff who are not directly involved in handling or reviewing shipments consisting of dangerous goods (DG)/hazardous materials (HazMat), but they are involved in creating airline, trucker or ocean bills of lading.
Is this person a “hazmat employee” and do they need to be certified by their employer?
It depends if they meet the definition of a “hazmat employee” according to the US DOT: which is an employee who in the course of their job could directly affect the safety of a dangerous goods shipment in transport. This includes anyone who physically handles shipments as well as those who may not even see the shipment IF their job involves inspecting the paperwork to determine the shipment’s compliance with the dangerous goods regulations.
What about someone who inspects the paperwork or inspects or handles dangerous goods shipments; do they need to get hazmat trained?
Yes, someone who inspects the paperwork or inspects or handles the actual dangerous goods shipments need to have full training and certification by the employer.
Does someone creating a bill of lading need to be hazmat trained?
Someone who doesn’t inspect the dangerous goods paperwork but creates or inspects other (non-DG) supplemental documents such as an air waybill, a trucker’s bill of lading or an ocean bill of lading (that is NOT also a dangerous goods declaration) may need some level of hazmat training. If the actions of those personnel directly affect the safety of a dangerous goods shipment in transport, then they must at least have a minimum of general awareness, safety and security training according to DOT rules. Furthermore, they must also have function-specific training regarding the dangerous goods function they are involved with.
Again, if someone is inspecting the paperwork to determine if it’s correct or inspecting the shipment, they must be fully trained at an acceptance level which is a term we use to identify those people responsible for determining if a shipment is “acceptable” according to the regulations.
For example, if an employee generates an ocean bill of lading that doesn’t contain any dangerous goods information or reference to dangerous goods info, then they don’t need training at all. It just depends, and ultimately it’s up to the employer to make that call as they are the only one who can certify the employee.
When in doubt, people working around dangerous goods would probably benefit from at least general awareness, safety and security training. Such training will help them understand the rigorous requirements for DG shipments, so that they can more effectively support the staff directly involved in processing these shipments.