Avoid Fines From the DOT – Make Sure Your Employees are Certified Signers
Many of our clients have contacted us with questions regarding HazMat training requirements and authorization for employees who are charged with signing manifests. Getting an authorized signature for a waste pickup is just as important as the shipping manifest itself. Without a certified signature from the generator, the generator is subject to fines from the DOT.
In an effort to keep you informed and compliant with Department of Transportation (DOT) and Hazardous Material Regulations (HMR), we have prepared the following guidelines:
Under the HMR, the U.S. DOT regulates shipments of hazardous waste (49 CFR Parts 171-180). Any personnel who prepare or transport hazard waste are subject to the hazmat employee training requirements identified in 49 CFR 172, Subpart H—Training. The training standard contains five elements—general awareness, security awareness, and function-specific training are required for all hazmat employees, while safety and security plan training are required only for certain hazmat employees and facilities [49 CFR 172.704(a)].
If a person signed the manifest…they are a hazmat employee. 49 CFR 171.8, “hazmat employees” are any worker who performs a pre-transportation function like classifying, packaging, marking, labeling, loading, unloading, or documenting hazmat shipments—must complete hazmat training within 90 days of hire. Once trained, hazmat employees must repeat training once every three years.
The hazardous waste manifest is a hazmat shipping paper, and is subject to 49 CFR 172, Subpart C: Shipping Papers. The person signing Box 15 of the manifest is subject to specific DOT requirements [49 CFR 172.204 and 172.205] and is therefore considered a hazmat employee. Personnel signing the manifest would require general awareness, security awareness training and function-specific training. Most of the questions that we receive are related to what level of function-specific training is required for a person signing a hazardous waste manifest?
Whoever signs the manifest is certifying that all aspects of the shipment are compliant with the HMR. When this person signs the manifest they are certifying that everything is compliant with the regulations. This means they must have comprehensive, function-specific training in classification, naming, packaging, marking, labeling, placarding, paperwork, and all other applicable transport regulations.
Certification language:
I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national government regulations.”
In order to certify that everything is accurate and in compliance with the regulations, the person must have comprehensive function-specific training in classification, naming, packaging, marking, labeling, placarding, paperwork, and all other applicable transport regulations.
As part of the service we provide to our customers, INGENIUM offers complimentary training classes that meet the elements required by DOT (General awareness/familiarization, Function-specific training, Safety training, Security Awareness Training). We also offer online based trainings, as well as private client trainings that can be held at a location of your choice.
For more information or to schedule a training, please visit or contact your Customer Service Representative directly at 800-464-3648.
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