What might seem like a minor mistake – mislabeling a hazmat package, misclassifying a hazardous material, or failing to include safety instructions – can lead to a hazmat incident that can not only harm the employees involved, but also harm anyone who might unknowingly come into contact with the materials.
It’s why the Pipeline and Hazardous Materials Safety Administration (PHMSA) requires hazmat employees to be trained properly before they are allowed to perform any function related to hazmat shipping. It says that regular training for hazmat employees is the single most effective way to reduce the risk of hazmat incidents caused by human error.
At the same time, it’s critical to understand that there might be situations where an untrained employee might have to handle hazardous materials – especially in remote areas where trained hazmat employees might not be available. As rare as these situations might be, it’s fundamental for hazmat employers to know what they can do in these situations to comply with Hazardous Materials Regulations (HMR) without impeding the hazmat shipping process in any way.
Virtual Supervision – The Solution to the Untrained Hazmat Employee Problem
Recently, the PHMSA was asked about a scenario where an untrained employee in a remote location has to handle certain pre-transportation functions – due to the lack of trained hazmat employees on site. The question raised was – whether HMR (49 CFR Parts 171-180) allows untrained employees to perform pre-transportation functions – if they can be virtually supervised by a trained hazmat employee via video call.
In its response, the PHMSA stated that an untrained employee can be allowed to perform pre-transportation functions under the virtual supervision of a trained hazmat employee – as long as the following conditions are met.
- The trained employee must be able to instruct the untrained employee – in real time – on how to perform their functions safely.
- The trained employee must be able to clearly observe how the untrained employee is performing their functions.
- If and when the untrained employee does something wrong or unsafe or fails to perform a function in accordance with the HMR, the trained employee must instruct them to take corrective actions immediately.
- The untrained employee must complete hazmat training (as specified in 49 CFR Section 172.704) within a period of 90 days.
The PHMSA’s response basically reiterates what 49 CFR Section 172.704 (c) (1) says. Whenever a new employee is hired to perform hazmat related functions and whenever an employee is required to perform hazmat related functions due to a change in their job functions, the employer must make sure that they perform their functions only under the direct supervision of a trained employee. The employer is also required to make sure the employee in question completes their hazmat training within 90 days.
How Virtual Supervision Can Help Untrained Employees Perform Their Duties Safely
An untrained employee can perform pre-transportation functions safely under the virtual supervision of a qualified trainer – as long as they are able to see and communicate with each other clearly.
The virtual supervision process can work in the following way.
- The trainer demonstrates how to do a specific function safely and in compliance with the HMR
- The untrained employee watches the demonstration and performs the function according to the trainer’s instructions
- The trainer observes the untrained employee and corrects them as and when needed
- The trainer continues to observe the untrained employee’s output, proficiency and efficiency, and offers constructive criticism as and when needed
The aforementioned process can go on until the employee in question demonstrates an understanding of the relevant regulations and is able to perform their job-related duties in a safe and compliant manner.
Hazmat University’s Online Training Courses – A Convenient Way for Hazmat Employees to Get Trained
At Hazmat University, we know how important it’s for hazmat employees to be properly trained. It is why we offer the most comprehensive, up-to-date online training courses for all modes of hazmat shipping. Designed by industry experts with extensive experience in hazardous materials management, our courses cover all the regulatory requirements for hazmat employees and are constantly updated to reflect the latest changes in the industry.
You can access our online training courses no matter where you are – at home, in the office, or on the go – as long as you have a device with an internet connection. Our courses allow you to learn at your own pace and convenience. You can skip over topics you already know, focus on areas where you need improvement, and learn in your own way.
To know more about our online hazmat training courses, call us today at 844-376-4076 or get in touch with us using our online contact form.
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