1 LEADER'S GUIDE 1724-LDG-E-Short DOT HAZMAT SECURITY AWARENESS TRAINING For the Department of Transportation's 49 CFR Subpart H Training Requirements Quality Safety and Health Products, for Today...and Tomorrow
2 THE REGULATORY COMPLIANCE KIT VIDEO SERIES This training program is part of a comprehensive series of programs on important regulatory topics. Many of these programs have been created to meet employee training requirements of specific OSHA, EPA and DOT regulations. The series includes programs on the following regulations and topics: - The Asbestos Standard. - The Bloodborne Pathogens Standard. - The Confined Space Entry Standard. - DOT Hazardous Materials Regulations (HMR). - Emergency Planning. - Forklifts/Powered Industrial Trucks Standard. - The "HAZWOPER" Standard (Hazardous Waste Operations and Emergency Response). - Hearing Conservation and Safety - Indoor Air Quality. - The Laboratory Standard. - The OSHA Lead Standards (Industrial and Construction versions). - Lock-Out/Tag-Out. - The OSHA Recordkeeping Standard. - The Personal Protective Equipment Standards. - The Respiratory Protection Standard. - Right-To-Know/The Hazard Communications Standard (Industrial and Construction versions). - Supported Scaffold Safety (Industrial and Construction versions). - Suspended Scaffold Safety (Industrial and Construction versions). - The CDC Tuberculosis Prevention Guidelines. Other products in the Regulatory Compliance Kit line include compliance manuals, employee booklets and posters which have been designed specifically to be used with the programs. These products can be used to satisfy OSHA, EPA and DOT compliance requirements for employee training.
3 WARRANTY/DISCLAIMER "This program has been created to assist companies that are endeavoring to educate their employees regarding the handling and transporting of hazardous materials. In 49 CFR , the Department of Transportation requires that employers provide up to five different types of education/training for their employees: General awareness training. Safety training. Function-specific training. Security awareness training. In-depth security training. This program addresses only the security awareness portion of this training. It does not satisfy compliance requirements for general awareness, safety, function-specific or in-depth security training. In addition to information about DOT's training regulations, the program presents information concerning the handling and transporting of potentially hazardous materials. The information contained in this program is the information available to the producers of the program at the time of its production. All information in this program should be reviewed for accuracy and appropriateness by companies using the program to assure that it conforms to their situation and recommended procedures, as well as to any state, federal or other laws and regulations governing their operations. There is no warranty, expressed or implied, that the information in this program is accurate or appropriate for any particular company's environment." Copyright 2004, The MARCOM Group, Ltd.
4 TABLE OF CONTENTS 1 INTRODUCTION TO THE DOT HAZARDOUS MATERIALS REGULATIONS (HMR) - Background - Major requirements 2 INTRODUCTION TO THE PROGRAM - Structure and organization - Objectives - Reviewing the program 3 PREPARING FOR THE PRESENTATION - Structuring the presentation - Additional training requirements - Setting up the class and classroom 4 CONDUCTING THE SESSION - The initial steps - Showing the program - Conducting the discussion - Concluding the presentation - Wrapping up the paperwork 5 OUTLINE OF MAJOR POINTS IN THE PROGRAM 6 ACCOMPANYING MATERIALS - Scheduling and Attendance Form - Quiz - Training Certificate - Employee Training Log
5 INTRODUCTION TO THE DOT HAZARDOUS MATERIALS REGULATIONS Background On May 15, 1992 the Department of Transportation (DOT) published Hazardous Materials Regulations (HMR) which enhanced training requirements and established a new Subpart H Training in 49 CFR. Since then several revisions have been made in both the content and structure of these training requirements, the most recent of which addresses the security of transported materials. The purpose of these regulations is to make sure that employees who handle or transport hazardous materials: Are familiar with the general provisions of DOT's regulations on handling and transporting hazardous materials. Are able to recognize and identify hazardous materials. Know how the regulations relate to specific functions they perform. Are aware of self protection measures they should take when working with hazardous materials. Are aware of accident prevention methods and procedures to be used when working with hazardous materials. Know what should be done in an emergency involving hazardous materials. Are aware of the security risks associated with transporting hazardous materials. Know what can be done to enhance the security of transported hazardous materials. Be familiar with their employer's Security Plan.
6 These regulations are located in the Hazardous Materials Regulations in 49 CFR parts There are two definitions that are essential to understanding the training regulation and how it applies to any facility's activities. These definitions deal with companies/facilities who are involved in handling and transporting hazardous materials... as well as the employees of these companies/facilities and how they are involved with hazardous materials: HAZMAT Employer - means a person (facility, company, institution, etc.) who uses one or more of their employees in connection with any of the following activities: Transporting hazardous materials in commerce. Causing hazardous materials to be transported or shipped in commerce. Being involved with any aspect of the packaging materials that are used in the transport of hazardous materials (such as producing, reconditioning or testing these packaging materials). This definition includes owners/operators of motor vehicles which transport hazardous materials. It also encompasses Federal and state departments and agencies. HAZMAT Employee - means a person who works for a HAZMAT Employer and who directly affects hazardous materials transportation safety. Activities that the DOT feels fit this definition include: Loading, unloading or handling hazardous materials. Working with hazardous materials' containers including testing, reconditioning, marking, etc. Preparing hazardous materials for transport. Having the responsibility for the safety of hazardous materials transportation. Operating a vehicle used to transport hazardous materials. This includes self-employed individuals who are involved in these activities as well as owners/operators of motor vehicles used to transport hazardous materials.
7 It is easy to see that because these definitions are so broad, in many facilities and operations the regulations will cover many types of employees from warehouse personnel to shipping/receiving groups, loading dock workers, truck drivers, train engineers, and others. It is also important to recognize that this regulation applies to any environment where these activities take place. This is not a regulation that is limited to industrial facilities, but includes laboratories, healthcare facilities and many other types of operations. Major Compliance Requirements There are five types of training required by 49 CFR General Awareness/Familiarization Training - should familiarize employees with the requirements of DOT's HMR (Hazardous Materials Regulations) as well as enable them to recognize and identify hazardous materials. Safety Training - must cover three major areas: Actions that can be taken to protect employees from hazards associated with materials they may be exposed to (this must include any specific measures an employer has implemented to protect employees from exposure). Methods and procedures for avoiding accidents, such as proper package handling. Emergency response. Function-Specific Training - must help employees to work safely with hazardous materials in their specific jobs. Security Awareness Training - must give employees an awareness of the security risks associated with transporting hazardous materials, as well as what can be done to increase the security of those materials.
8 In-Depth Security Training - should familiarize employees with their employer's Security Plan and its implementation, including: The company's security objectives. Specific security procedures. Actions to take in case of a security breach. The organizational security structure. In addition to the training requirements themselves it is important to be aware of several other aspects of this regulation. For instance, the burden of providing employees with entirely new training can be relieved somewhat if a facility is already conducting OSHA or EPA training involving hazardous materials (such as "Right-To-Know" or "HAZWOPER" training). However, not only must all HAZMAT Employees be initially trained as required in 49 CFR, but retraining is required for these employees at least once every three years. In addition, training must be done whenever new procedures, information or regulations occur requiring employees to receive updated training. Also, the Department of Transportation requires that formal records be kept of the training given to each employee under 49 CFR. These records must include: The HAZMAT Employee's name. The date when the employee's most recent training was completed. A description or copy of the training materials that were used... or a reference to the location to where these materials can be found. The name and address of the person providing the training. Certification by the employer that the HAZMAT Employee has been trained and tested.
9 INTRODUCTION TO THE PROGRAM Structure and Organization Information in this program is presented in a definite order so that employees will see the relationships between the various groups of information and can retain them more easily. The sections included in the program discuss: The need for HAZMAT security training. A facility's internal vulnerabilities. Securing a facility. Securing hazardous materials themselves. Preparing to ship hazardous materials. Protecting HAZMAT shipments. Unloading shipments of hazardous materials. These sections include examples and other references that will help employees to relate the information in the program to their work environments, be aware of the security risks associated with handling and transporting hazardous materials and know how those risks can be addressed. Objectives This training program is designed to make employees aware of the security risks associated with handling and transporting hazardous materials, acquaint them with methods that can be used to enhance transportation security, and help them to recognize and respond to possible security threats. Upon completion of the program, employees should:
10 Understand the security risks that are associated with handling and transporting hazardous materials. Understand why threats from individuals within a facility's own workforce are often the most dangerous. Know some of the methods and procedures that can be used to make a facility more physically secure. Understand how hazardous materials themselves can be secured within a facility. Understand what they should do if they encounter a security threat within their facility. Know how to secure hazardous materials for shipment. Know some of the methods that are used to protect HAZMAT shipments. Understand the procedures that should be used when unloading hazardous material shipments.
11 Reviewing the Program As with any educational program, the presenter should go through the entire program at least once to become familiar with the content and make sure the program is consistent with company policy and directives. Additionally, because this program addresses a federal regulation, the presenter should check to make sure that the program's contents do not conflict with any other regulations that the facility is subject to in this area. An Outline of Major Program Points section is included in this Leader's Guide to help with this task and for general reference. As part of this review process, you should determine how you will conduct your session. The use of materials, such as handouts, charts, etc., that may be available to you needs to be well thought out and integrated into the overall program presentation.
12 PREPARING FOR THE PRESENTATION Structuring the Presentation In conducting this education session, you should proceed with a friendly and helpful attitude. Remember that the trainees are looking to your experience and knowledge to help them relate to the situations shown in the program. It is important to let the trainees interact with you and each other during the training session. Stimulating conversation within the group is one of the best things you, as the presenter of the program, can do to help everyone get as much as possible from the session. Be alert for comments that could help in this area in future sessions and make note of them. As the presenter, you also should: Keep the session related to the topic of handling and transporting hazardous materials safely and securely and DOT HAZMAT regulations. Relate discussions to your company's operations, procedures and responsibilities. Prevent any one person or small group of employees in the session from doing all the talking. Get everyone involved. Ask questions of those who don't participate. Clarify comments by relating them to the key points in the program. Use the Outline of Major Program Points section, included in the guide, as well as the information included in the quiz, as the basis for answering any questions. If you don't know the answer, say so. Tragic results may occur should you provide incorrect or inaccurate information.
13 Remember, this is a positive program on keeping hazardous materials secure while they are stored and transported. Make sure your attitude and words reflect this, and that the emphasis is always on providing the information needed by the attendees to recognize the security risks in handling and transporting hazardous materials as well as what can be done to address these risks. Additional Training Requirements As we have discussed, in addition to this security awareness training you are required to give your employees several other types of DOT HAZMAT training as well. This can include: General awareness training. Safety training. Function-specific training. In-depth security training. Since the need for other types of training is mentioned in the program, you might want to discuss with attendees how your facility will be dealing with this additional training, including other courses you may have scheduled (if this information is available). Setting Up the Class and Classroom Remember, there are a number of things that must be done to set up the class as well as the classroom. These fall into several groups of activities, and include: Scheduling and Notification Use the enclosed form to schedule employees into the session. Make sure that the session is scheduled so that it fits into your attendees' workday.
14 Send out notification of the session well in advance, to give people enough time to incorporate it into their schedule for that day. If possible, post a notification on bulletin boards in the affected employees' areas. The Classroom Schedule the room well in advance. Make sure the room can accommodate the expected number of attendees. Check it again on the day of the program to make sure there is no conflict. Make sure the room can be darkened, and won't create a glare on the television screen. Locate the light controls and test them. Make sure the power for the videotape or DVD player you are using operates separately from the room light. See if you can control the room temperature. Know where the closest restrooms are located. Assure that the room is free from distracting noises. Make sure emergency exits are marked and known to the attendees. Seating Make sure everyone can see the screen from their seat. Make sure everyone can hear both the videotape/dvd and you (when you speak). Check to see that seating is such that writing can be done easily. Make sure the seating arrangement allows eye contact between attendees, and between you and attendees. Equipment and Materials Make sure the videotape or DVD player, monitor, and all appropriate cables and extension cords are available. Make sure a stand or table is available and is of appropriate height for all attendees to easily see the monitor.
15 If you plan on using a chartpad, blackboard, or other writing board, make sure it is available, easy to see, and you have the proper writing instruments. Make sure you have 6" x 8" index cards or other materials to be used as name tents for attendees. Make sure you have made up a sufficient number of copies of the quiz, as well as any other handouts you are using. Final Check Make sure equipment is in the room prior to the scheduled session. Check to see that the room is set up properly. Check equipment prior to the presentation to assure that it works. Make sure extension cords, etc. are taped down, if need be, to avoid tripping. If you are using the videotape version of the program, run the leader up to the point where the program begins.
16 The Initial Steps CONDUCTING THE SESSION In conducting the session remember the positive nature of this presentation. Everyone is attending in order to learn more about the DOT Hazardous Materials Regulations and how the security risks associated with HAZMATs are addressed through a facility's Security Plan. Initially, you need to: Introduce yourself as the session leader. State the title of the program, DOT HAZMAT Security Awareness Training. State the purpose of the session (to learn more about the DOT HAZMAT regulations, the security risks associated with handling and transporting hazardous materials, and how those risks can be addressed). Inform the attendees when there will be breaks (if you plan them) the location of exits and restrooms and if water, coffee, or other refreshments will be available. Make sure all of the attendees have signed in on your scheduling and attendance sheet. Remember, it is very important to document peoples' attendance at the session. Once this housekeeping is done, it is time to move to the meat of the session. First, the attendees need to be informed about the objectives of the session (this is where you can use a flip chart or board to list the objectives, which should be done prior to the class starting). This listing should be preceded with some introductory remarks. Your own words are always best, but the remarks should go along the lines of the following:
17 "Today we are going to talk about the Department of Transportation's regulations on handling and transporting hazardous materials securely, and what those regulations mean to us in our environment." "Every day millions of tons of hazardous materials are safely transported by trucks, trains, plains, ships and pipelines to facilities throughout the country. In the wrong hands, however, they can and have been used as weapons against us." "Unfortunately, it took the September 11 th tragedy for us to realize that we need to have the hazardous materials that we handle and transport secured twenty-four hours a day, seven days a week." "As part a comprehensive strategy to protect the United States from future terrorist attacks, the DOT has revised its regulations to require all companies that transport or cause the transportation of hazardous materials to provide security training for their employees. One type of this training, In-Depth Security Training is what we are addressing today." "We need to be aware of where hazardous materials exist in our facility and how terrorists might try to reach them. We need to know the various types of security measures and procedures we have in place, and what our roles in those procedures should be, as well." "We also need to be aware of the risks that occur when hazardous materials are prepared for transport, are en route to their destination, and when they are unloaded and stored. We also need to know what can be done during these processes to safeguard HAZMATs." "Learning more about how to handle and transport hazardous materials safely and securely is the focus of this session. In order to do that, these are the things we would like to accomplish today (verbally reference the Objectives list provided in the second section of this manual, or point to the board or chart where you have written them down)."
18 Once the objectives have been provided, you are ready to show the program. However, you need to let the attendees know that they will be taking a quiz at the end of the session. It needs to be emphasized that the quiz is being used to see if the session is effectively transmitting information to them in a way they will remember. The quiz will also permit employees to receive the certification regarding this training that the DOT requires. Showing the Program At this point, you need to introduce the title of the program once again, DOT HAZMAT Security Awareness Training, darken the lights if necessary, and begin the showing of the program. If you are using the DVD version of the course you have several options as to how you can move through the program and what employees see. The DVD menu has two selection bars: Play. Contact Us. To just play the program from beginning to end, select Play. If you would like information on other programs and products that are available from Training Network you can select Contact Us for information about how to contact us. Conducting the Discussion After the program has been shown it is time for the group discussion on the information contained in the session. Care must be taken to make sure that the discussion is kept to the general topic of the DOT Hazardous Materials Regulations, and how to handle hazardous materials safely and securely. There are several ways to conduct these discussions. They include:
19 Calling for questions from the attendees and using these questions as the basis for the discussion. Leading the discussion through the points covered in the program, using statements such as: "One of the things that the program discussed was the types of HAZMATs that might be used as weapons. What materials in our facility would fall into this category?" "The program discussed a number of procedures that can be used to help prevent a security breach from within. Who can list some of those procedures?" You should use the discussion format that you are most comfortable with. The Outline of Major Program Points section in this guide and the questions and answers in the master copy of the quiz should be used as a basis for this discussion. Remember, you have allocated a limited amount of time in which this discussion can take place. It is important to blend the attendees' questions and areas of obvious interest with the objective of trying to touch on each major area within the program in the discussion. By touching on each area, the attendees are much more likely to retain the information presented in the session. Concluding the Presentation Once discussion has concluded (whether naturally or you have had to bring the discussion to a close in order to complete the session within the time allowed), it is time to give the quiz. Again, remind the attendees that the quiz is meant to help determine how effective the presentation of the information is, and that they will be graded. Let them know that they have approximately five minutes to complete the quiz. At the end of the five minute period, remind the attendees to date and sign their quizzes and then collect them. The attendees should be thanked for attending the session and reminded of any other sessions in the educational program that they may be attending. They can then be dismissed to return to their normal activities.
20 *(An alternative to this approach is to give the quiz immediately after showing the program, then use a review of the quiz as a basis for your group discussion.) Wrapping up the Paperwork Before much time has passed, and the subject matter is fresh in your mind, several areas of paperwork must be completed. First, check to make sure that all attendees signed the Scheduling and Attendance Form. Also, make sure that you have a quiz from every attendee, dated and signed. Unlike many other regulations, 49 CFR requires that employees who receive this training are also tested on it. The Department of Transportation has also included rigorous recordkeeping requirements. The Scheduling and Attendance Form will serve to provide overall information on who you have trained and on what date. However, you should also begin (or update) your records for each individual employee, showing what training they have received and when it was given. This can be done manually or via computer records (there is a form that can be copied and used for this purpose in the Accompanying Materials section of this guide). Remember, the fact that an employee has received the proper training and has been tested must be certified in writing. There is also a form that can be used for this purpose in the Accompanying Materials section of this guide.
21 OUTLINE OF MAJOR PROGRAM POINTS The following outline summarizes the major points of information presented in the program. The outline can be used to review the program before conducting a classroom session, as well as in preparing to lead a class discussion about the program. On February 26, 1993 a foreign terrorist cell detonates a rented van filled with a fertilizer-based explosive in the parking garage of the World Trade Center. The blast kills six people and injures more than one thousand, but fails to topple the tower. On April 19, 1995 a domestic militant group detonates a truck filled with an explosive mix of fertilizer and diesel fuel outside the Alfred P. Murrah building in Oklahoma City. Sixty-eight people were killed, including nineteen children. Every day millions of tons of hazardous materials are safely transported by trucks, trains, planes, ships and pipelines to facilities throughout the country. In the wrong hands, however, they can and have been used as weapons against us. Unfortunately, it took the September 11 th tragedy for the country to realize that we need to protect ourselves every day from terrorists who murder and destroy in unprecedented ways. As part of a comprehensive strategy to protect the United States from future terrorist attacks, the Department of Transportation has added a number of security requirements to its HAZMAT regulations. As part of these changes all companies that transport or cause the transportation of hazardous materials must provide security awareness training for their employees.
22 This includes everyone involved in the transportation of hazardous materials: From the manufacturing and testing of shipping containers. To the unloading of the materials at their final destination. This security awareness program will discuss: Security risks involved in handling and transporting hazardous materials. How to recognize potential security threats. Methods of enhancing HAZMAT security. Specific actions to take during a security breach or attack. This training is critical. You and your coworkers may be the first line of defense in preventing a terrorist attack. Years ago terrorists tended to rely on conventional military weapons. But today they have added hazardous materials to their arsenals, because: Many types of HAZMATs are readily available. A number of HAZMATs posses the ability to cause major damage and inflict mass casualties. But who should we be on the lookout for? It is important to remember that terrorists can have many faces. They may be: Members of a highly trained foreign cell. From a domestic militant organization. A misguided individual who has his own twisted agenda. In many ways terrorists are like any other type of criminal. So some of the same precautions that you would use to safeguard consumer goods also work with hazardous materials.
23 Enhancing security requires an examination of a facility from the inside-out. Internal threats can often be the most dangerous. Employees have knowledge of a facility's layout and security procedures, and may even have access to sensitive areas. So a misguided worker can pose an extremely serious threat. Internal security is an ongoing process. It starts with background checks being performed before a new employee is hired. Typical internal security measures also include: Conducting spot-checks of personal vehicles and lockers. Having visitors show identification and sign in. Accompanying visitors while they are in the facility. If your facility uses other companies to transport hazardous materials, the security measures that they have in place should also be checked regularly. Unintentional security breaches can provide terrorists with information that is useful to their plots as well. Terrorists can intercept , so confidential information shouldn t be sent over any computer network unless the messages can be encrypted. Files that detail your company's security measures should only be stored on computers that are protected by firewalls. Sensitive information shouldn't be discussed on cell phones either. It's possible for a terrorist to eavesdrop on your conversation. And never discuss the hazardous materials that are handled at your facility, or your facility's security measures, in public. You don't know who may be listening.
24 To do your part to enhance HAZMAT security, you need to know: What hazardous materials are stored at, and transported to and from, your facility. Which of these substances could be used as weapons. Potentially dangerous HAZMATs include: Flammables. Explosives. Corrosives. Reactive substances. Materials that are toxic to people or the environment. The DOT Emergency Response Guidebook is an invaluable resource for determining the characteristics and hazards of these types of materials. By referring to the green section it is easy to see how one of the substances could threaten the health and welfare of an entire community. If your company handles biological materials or infectious waste, it is also important to determine if these substances could be used as weapons. Once you recognize what hazardous materials in your facility could be targeted by terrorists the next thing to look at is how a security breach or attack could take place. Protecting a facility from terrorism is much easier than protecting individual HAZMAT shipments, since you can use a number of methods to prevent unauthorized access, such as: Barriers, like fencing. Bright lights. Security cameras. Alarm systems. If possible, entry to a facility should be through a single, wellguarded accessway. Parking for visitors should be well away from hazardous materials storage areas.