IATA Dangerous Goods Training /Focused Training For What You Ship

By:  Arthur Mahoney, M.S., CHMM, REA

May 5, 2008

As a shipper of hazardous materials/dangerous goods* by air, are you meeting your legal requirements? Are your employees properly trained and certified to ship hazardous materials/dangerous goods? Was the training they previously received focused on what they actually ship? You may have heard that the maximum civil penalty for a hazardous materials/dangerous goods* violation was recently increased from $32,000 to $50,000. In addition, the maximum criminal penalty of 5 years imprisonment was increased to 10 years for certain violations.

To ensure compliance with hazardous materials/dangerous goods* air shipping regulations, the Federal Aviation Administration (FAA) inspects shippers and carriers of hazardous materials/dangerous goods*. FAA inspectors say that the most common violation of hazardous materials/dangerous goods* shippers is failure to train employees. Additional common violations include the improper classification, failure to use acceptable packaging or follow packaging instructions, and improper labeling of hazardous materials/dangerous goods*.

Do not delay compliance. Now is the time to act and ensure your employees are adequately trained.

Dangerous Goods Commonly Shipped by Technology Companies

Biotech and Pharmaceutical:

  • Dry ice
  • Infectious substances (e.g., Adenovirus, E Coli, etc)
  • Genetically modified microorganisms
  • Pharmaceutical intermediates (e.g., small molecules)
  • Fixing agents (e.g., formalin)

Other High Tech Industries:

  • Research chemicals
  • Flammable, corrosive, toxic chemicals
  • Samples
  • Compressed gases
  • Magnetized materials
     

Training Requirements

Who Must be Trained:

Is everyone who is required to be trained at your company actually trained? Very often, Shipping and Receiving personnel are tasked with shipping dangerous goods packages which they did not personally package. Laboratory personnel without the proper training may have packaged the material- potentially putting your company at risk. Per 49 CFR and HM-223**, training must be provided to employees who affect hazardous materials/dangerous goods* transportation safety. This includes employees who:
 

  • Determine a material's hazard class(es);
  • Select the packaging;
  • Fill and close a packaging;
  • Mark and label a package;
  • Prepare or review shipping papers and emergency response information;
  • As an importer of hazardous materials/dangerous goods*, provide the shipper with shipping requirements that will apply to the transportation of the material within the United States;
  • Certify that a hazardous material/dangerous good* is in proper condition for transportation;
  • Load, block, and brace a hazardous material/dangerous good* package in a freight container or transport vehicle;
  • Segregate a hazardous materials package in a freight container or transport vehicle from incompatible cargo.
  • Selecting, providing, or affixing placards for a freight container or transport vehicle to indicate that it contains a hazardous material/dangerous good*.

How Often is Training Required:

Initial training is required within 90 days of the job function. Retraining is required with 24 months of initial training. Additionally, employees must be retrained when there are changes in the regulations which impact them.


What is the Required Content of the Training:
 

  • General familiarization training
  • Function-specific training
  • Safety training
  • Security awareness training


Testing and Certification:

Employees must be tested and certified. But the testing can (and should) be customized to the functions of the employee.

Our Training Solution


Focused on What You Ship:

Save money and time. You do not need to send your employees to offsite training courses which may last three days! The program I offer can often be completed in a single 1-day session at your facility. In addition, the testing and certification can also be customized to the specific job functions.


Added Value: Your Very Own Shipping Guidelines:

Included in the training are shipping guidelines/checklists customized to the types of materials you actually ship. These may also include procedures and forms for carriers that you use (e.g., FedEx, World Courier, DHL). These are included in a customized manual for your shipping personnel.



More Added Value: Packaging Solution Consultation:

Working with a number of packaging vendors over the years, I can assist your organization in developing customized packaging solutions.
 

An Easy Way to Comply

Contact me and I would be happy to provide you a quotation for an IATA Dangerous Goods Training Program specific to the dangerous goods that you ship.

What makes my program especially valuable is that it is specific to the dangerous goods that you ship and it is presented by me, an expert in the field.

Other related transportation training topics include:
 

  • 49 CFR for Shipper's by Ground/Highway,
  • Hazardous Waste Management and Manifest Preparation

Other commonly requested training includes:
 

  • Bloodborne Pathogens (annual requirement)
  • Hazard Communication
  • Chemical Hygiene Plan
  • General Safety
  • Laser Safety
  • Biological Safety
  • Radiation Safety
  • Many others, please contact me
     

Served by an Expert in the Field

My credentials include:

  • 17 years of experience assisting public and private companies to comply with environmental and safety laws and regulations
  • Educator of safety professionals
  • MS in chemistry from University of California, Berkeley
  • Certified Hazardous Materials Manager (Masters Level)
  • Registered Environmental Assessor
Please feel free to contact me about other services at 650.347.0417 or e-mail at art@hazardsolutions.com.

Kind Regards

Arthur Mahoney, MS, CHMM, REA

Hazard Solutions LLC
326 Sonora Drive, San Mateo, CA 94402
email: art@hazardsolutions.com
website: http://www.hazardsolutions.com/
Software website: http://www.hazardsolutions.com/software/


--EHS Compliance, Training and Data Management Solutions—

 

*Dangerous goods includes articles or substances which may be hazardous (in air transport). The definition of dangerous goods is found in the Dangerous Goods Regulations, published by the International Air Transport Association (IATA) . Dangerous goods are synonymous to hazardous materials, which is the term used to describe hazardous substances in 49 CFR.


**HM-223 clarifies the many pre-transportation functions which necessitate training.

Disclaimer: The information presented above should not be construed in any way as legal advice or an interpretation of regulations. It is meant to provide basic information about topics that may affect clients and colleagues.

 
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