When it comes to shipping hazardous materials, there are very specific regulations that must be followed. While the regulatory requirements can be daunting for the uninitiated, the required certifications are essential to safely shipping hazardous materials and are in place to ensure the public’s safety. It’s important hazmat employees have the proper certification of training in order to safely ship these materials that shows proof of theire familiarity and knowledge.
At CARGOpak Corp, we specialize in customized solutions for shipping hazardous materials. We also provide dangerous goods training for compliance with the IMDG Code for vessel shipments and ICAO/ IATA training for air shipments, to clarify, Dangerous goods is the international equivalent term for hazardous materials. The hope of this article is to provide you with a short guide to the credentials or certifications needed to ensure the safe transport of hazardous materials domestically in the US and internationally by vessel and air.
Hazmat certification
Domestically in the US, the Pipeline and Hazardous Materials Safety Administration (PHMSA) is the branch of the Department of Transportation ( DOT) that is responsible for creating the regulations for all shippers and carriers of Hazardous Materials. Let's start off by saying it is mandatory for all companies involved with the transport of hazardous materials to comply with the regulations found in Title 49 of the Code of Federal Regulations. https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C
A key component for any employee who handles, offers or prepares Hazardous Materials is their Hazmat employee training certification. This is issued by their current Hazmat employer showing proof of their DOT regulatory compliance training. It is not transferable. This DOT basic requirement applies to all hazmat employees, even if they only ship internationally. Here's a snippet from the Hazardous Materials Regulations;
§171.22 Limitations on the use of international standards and regulations. A hazardous material that is offered for transportation or transported in accordance with the international standards and regulations authorized in paragraph (a) of this section - (1) Is subject to the requirements of the applicable international standard or regulation and must be offered for transportation or transported in conformance with the applicable standard or regulation; and (2) Must conform to all applicable requirements of this subpart.
This required certification proves their understanding of DOT hazardous materials regulations as it pertains to their particular job function e.g. identify, prepare, package, mark, label, load, transport, or unload hazardous materials safely to name a few. What if the Hazmat employer doesn't have the expertise to train it's employees? The DOT permits the usage of third party trainers such as CARGOpak. https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C/part-172/subpart-H/section-172.702
Other Credentials
In addition to this certification, domestically, there are several other requirments you may need depending on what type of transport you are involved with. For instance, if a company is planning on transporting inter-state using their own vehicles, they would need to consult another branch of the DOT called the Federal Motor Carriers Safety Administration ( FMCSA). Furthermore, if you are operating motor vehicles that weigh more than 10K lbs., then the driver must have a valid Commercial Driver’s License (CDL) with a “Hazmat Endorsement” added to it. Here's an important link explaing the required details: Transporting Haazardous Materials By Highway - New Carrier Information Guide (dot.gov)
If you are offering a material that requires a DOT "Special Permit", each person involved with the shipment must be trained and certified they know the details and restrictions of the particulars associated with it. This even applies to shippers who only reship the material.
Each "Hazmat employee", as defined in§ 171.8, who performs a function subject to this special permit must receive training on the requirements and conditions of this special permit in addition to the training required by sub-parts 172.700 through 172.704.
Local certifications
Depending on where your shipments originate from or where they are headed, additional state or local credentials may be required before your shipment can be deemed legal on public roads or highways. For example, some states require special licenses for drivers who transport hazardous materials intra-state (within their borders) such as New York's HM Permit (Hazardous Materials Permit).
It is also important to note that all carriers must keep records documenting their compliance with various hazardous materials laws and regulations including those set by OSHA (Occupational Safety and Health Administration), EPA (Environmental Protection Agency), PHMSA (Pipeline and Hazardous Materials Safety Administration), as well as state and local governments. Additionally, certain types of shipments require specific shipping papes such as manifests or bills-of-lading which outline the contents of each shipment being transported by the carrier. All documents should be kept or a minimum of two years in case any questions arise during inspections by regulatory agencies or law enforcement officials.
International certification
As with the domestic regualtions, which require general awareness training as well as, function specific and safety training, if shipping by vessel, a shipper must ensure compliance with the International Maritime Organization's IMDG Code part 1.3.1.
"Shore-based personnel engaged in the transport of dangerous goods intended to be transported by sea shall be trained in the contents of dangerous goods provisions commensurate with their responsibilities.
Employees shall be trained in accordance with the provisions of 1.3.1 before assuming responsibilities and shall only perform functions, for which required training has not yet been provided, under the direct supervision of a trained person. Training requirements specific to security of dangerous goods in chapter 1.4 shall also be addressed.
The IMO has a requirement that is often overlooked by shippers involves the "Container Packing Certificate". When dangerous goods are packed or loaded into any container or vehicle, those responsible for packing the container or vehicle shall provide a "container/vehicle packing certificate" specifying the container/vehicle identification number(s) and certifying that the operation has been carried out in accordance with the requirements of part 5.4.2.1. This involves ensuring inspection of the container for sea-wothiness and all the dangerous goods have the appropriate shipping papers, are marked and labeled correctly and are loaded, segregated, placarded, Proper training for blocking and bracing is often overlooked.
Starting this year, the International Civil Aviation Org. (ICAO), and subsequently the airline industry ( IATA), have implemented "competency based training". Essentially this is another way of describing function based training, however, according to the 2023, IATA Dangerous Goods Regulations Edition 64, Part 1.5-Training Requirements, DG employees must now demonstrate their competency. CARGOpak's view on this is, if the function based training is done correctly, training class attendees will be showing their competency. the FAA, which is the enforcement branch for air transprt in the USA, still only recognizes the requrements published in CFR 49 and are still considered the law of the land.
Fill out an assessment for hazmat certification today
If you need hazmat training courses, CARGOpak Corp is the leading solution. We have over 35 years of industry experience and incomparable knowledge of shipping regulations for different products and modes of transportation.
We offer webinars, on-site training, and computer-based training for clients who offer, handle, or receive hazmat materials. You can also find an array of helpful resources related to US DOT compliance, Pipeline, and Hazardous Materials Safety Administration compliance, and Lithium Battery Guidance for 2023.
Get in touch with CARGOpak Corp!
As outlined above, there are many credentials and certifications required for shipping hazardous materials and dangerous goods safely & legally in accordance with DOT regulations & other applicable laws & guidelines set forth by OSHA, EPA, IMO, ICAO and IATA. At CARGOpak Corporation we understand just how complex these requirements can be, so let us help you make sure that everything is taken care of properly when it comes time to ship your hazardous material or dangerous goods cargo! Contact us today for more information about our services!
