DOT HAZMAT Training Keeps Costly Fines at Bay

BACKGROUND:

Cetylite Inc. has specialized in the manufacturing of sprays, liquids and gels for over sixty years that are widely distributed to the wholesale drug, medical, dental, and veterinary fields. Products include prescription topical anesthetics, concentrated infection prevention products, and a host of other complimentary dental and medical products. The company, which employees 30 in its Pennsauken, NJ facility, has annual sales of over $3M.

CHALLENGE:

Many of Cetylite’s products fall within DOT 49CFR 172.700 regulations. The company wanted to have its procedures reviewed to assure it was compliant with this very complex regulation pertaining to HAZMAT shipments.

In 2011 Cetylite worked with NJMEP on a Leadership Training Program that included Goals, Lean Admin, SWOT and Internal Communications. When it was time to tackle 49CFR 172.700 compliance, they chose a trusted resource, NJMEP.

SOLUTION:

NJMEP laid out a two-part plan—first reviewing the current situation as it pertains to the purpose and scope of 49CFR 172.700 and second, provide the specific training set forth in the regulation. NJMEP’s program would provide Cetylite’s employees with the tools needed for compliance with the code. The objective of the training would be to assure the participants are able to recognize what the requirements are and how to ensure they are satisfied. Hazardous materials regulations training (49 CFR) is an important step in shipping safely and avoiding fines. 49 CFR training is always based on the current 49 CFR regulations which are continually updated.

49CFR 172.700 consists of the following elements: a hazardous materials table, special provisions, hazardous materials communications, emergency response information, training requirements, and security plans. Cetylite’s policies and procedures would be evaluated in the context of these points. Upon completion of the review, training would begin.

Employee training is required to be a systematic program that ensures a hazmat employee has familiarity with the general provisions of code, is able to recognize and identify hazardous materials, has knowledge of specific requirements applicable to functions performed by the employee, and has knowledge of emergency response information, self-protection measures and accident prevention methods and procedures. Initial training must be completed within 90 days after employment or a change in job function. Training is to be conducted every 3 years.

Upon completion of the review and training Cetylite became fully compliant with regulation 49CFR 172.700.

Its employees who worked hazardous materials understood:

• The purpose and use of hazardous materials table, which lists and classifies the materials that the DOT has designated as hazardous materials for purposes of transportation and also prescribes the requirements for shipping papers, package marking, labeling, and transport vehicle placarding applicable to the shipment and transportation of those hazardous materials.
• Shipping Related Requirements:
  • Detailed information on shipping label requirements
  • Preparation and retention of shipping papers
  • Description of hazardous material on shipping papers
  • Additional description requirements
  • Shipper’s certification
  • Hazardous waste manifest
  • Marking requirements
  • Labeling
  • Placarding (placing a poster or sign for public display)
  • Emergency Response Information
  • Record keeping

RESULTS:

As the employer, Cetylite is responsible for meeting the record keeping responsibilities as prescribed in the code. After the review and training the company’s record keeping procedure was confirmed compliant.

When surveyed by NIST on the impact the DOT HAZMAT review and training had on the company, Cetylite reported:

• They achieved a cost savings of $22,000
• Invested $25,000 in Workforce Practices and $10,000 new processes

In addition, Cetylite has avoided fines in excess of $1000.00 per day for having untrained workers performing hazardous material transportation duties.

When asked about working with NJMEP, Donna Pacifico, Chief Administrative Officer and HR Manager for Cetylite replied, “Compliance in our industry is critical. Incompliance is costly. When we needed to meet our training requirements and have our procedures reviewed and evaluated we brought in NJMEP. We are confident, as a result of their work, we meet all requirements to be in compliance with 49CFR 172.700 and will not have any problem or face any fines.”

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