If you’re an employer whose employees meet the definition of a hazmat employee, you may already know the importance of proper hazmat training. Not only is stringent training required by law, which is enough of a reason to make sure your employees are properly trained and certified, this training allows your employees to perform their duties much more safely, effectively, and efficiently. What you may not know, though, are the best tips for complying with the hazmat training record retention requirements.
This might seem like a secondary concern. After all, isn’t your main priority making sure your employees are properly trained in all of their respective functions related to the hazardous materials that will be received and/or offered, such as the classification, identification, packaging, marking, labeling, documentations just to name a few? It is, but that doesn’t mean you can afford to overlook maintaining proper records.
In the era of COVID-19, adhering to record retention is more important than ever. Beyond conforming with hazmat training record retention requirements, what follows are recommended protocols for record retention in the era of COVID-19.
Migrating to Digital Record Retention in a Post COVID-19 World
Replacing the physical records of your hazmat employees with digital records is a prudent idea for two reasons.
Less Risk of Viral Transmission
Firstly, the process of cataloging, maintaining, and accessing physical records requires human intervention at every level. At a time when a pandemic is spreading, it is not advisable to encourage any activity that requires sustained contact with people.
With digital records, the whole process can be simplified and the need for human intervention can be minimized to a serious extent. People can access the records they want using their smartphone or computer, as long as they are authorized to do so. It can lower the risk of viral transmission through inanimate objects as well as people-to-people transmission considerably.
The Emergence of Digital Workplaces
Secondly, experts believe that the COVID-19 pandemic might cause businesses to undergo a paradigm shift in terms of how they operate. Many of the strategies that are being followed now – allowing employees to work from home, replacing in-house storage solutions with remote, cloud-based storage solutions, and minimizing the need for human intervention in business processes – might be permanently adopted by many businesses.
If you want to get ahead of – or at the very least keep up with – your competition, you have to get used to the idea of a digital workplace, where physical records might no longer be seen as a necessity.
What are Hazmat Training Record Retention Requirements?
These hazmat record retention requirements are the legal requirements surrounding how you maintain your employees’ certification records. They can be found in Title 49 Code of Federal Regulation, Subpart H, Section 172.704.
This section states, “Each hazmat employer must create and retain a record of current training of each hazmat employee…” It goes on to list the specifications of the retention requirements, which include:
- You must keep detailed records of current training for each individual you employ defined as a hazmat employee.
- These records must include the previous three years.
- You must keep these records for ninety days after a hazmat employee is no longer employed or does not perform a function related to hazmat.
- Records must be made available upon request at a reasonable time and location, if requested by an authorized official from the Department of Transportation or someone explicitly granted permission to enforce the Hazardous Materials Regulations (HMR).
Now, these are the regulations surrounding how to keep hazmat training records, for how long, and under what circumstances you can be called upon to present them. What about the records themselves? What must the record include?
There are five pieces of information that must be included in hazmat training records. These include:
- The employee’s name
- The completion date of the employee’s most recent training
- A description, copy, or the location of the employee’s training materials used to meet the requirements
- The name and address of the individual or business that administered the training
- The hazmat training certification
Now that you know what records must be maintained, it is time to look at best tips for complying with the hazmat training record retention requirements.
Best Practices for Keeping Records
Much of the following advice depends on how you store your employees’ records. If your employees opt for online hazmat and dangerous goods training, then you’ll likely store everything digitally. If they opt for more traditional, in-person training, then you might stick to the tried and true filing cabinet.
Make sure to do the following if you’re storing your employees’ certifications digitally:
- Create a series of certification folders with a clear hierarchy – company → division → employee → year → certification
- Store these folders on a cloud storage device
- Make sure all of your data is secure and protected by 256-bit encryption
- Create automated reminders for which employees’ certifications are close to expiring
- Make sure all documentation is saved as a PDF rather than as a .doc or .docx – this will eliminate any potential questions of whether the certifications are authentic or not
By far the most important of the above best practices is storing everything on a cloud storage device. While the remaining tips are smart ideas, storing your employees’ hazmat training records remotely removes the possibility of data loss. You don’t want to lose these records in the event of a local server crash or hack.
If you’re storing your employees’ certifications in a filing cabinet, make sure to take the following precautions:
- Create a clear hierarchy for all information, similar to the one that you would create digitally but adapted to physical storage
- Create photocopies or backups of all training records
- Store these photocopies in another location
- Make sure your filing cabinet is secured by a non-breakable lock
- Have a clear system for identifying which employees are in need of training
- Have employee’s manager sign all certifications and proof of training
Online Hazmat Training Programs – The Need of the Hour
One of the best ways to simplify the process of record retention is to encourage your hazmat employees to undergo online training programs. Taking advantage that these courses are online there are great saving by taking more than one mode of transport at one time, such as online multimodal training rather than in-person or onsite programs.
Online hazmat training programs are affordably priced, easily accessible, and can be completed at the trainee’s own pace. The certificate of completion can be printed out at the end of the training program. You can store these digital certificates on your cloud-based server securely and access them whenever you want to. You can also install a file security system to make sure the records can only be accessed by those who have the authority and clearance to do so.
Online Training Programs for Hazmat Shippers and Employees
As the COVID-19 pandemic continues, we realize that our mission to keep people safe is more important than ever. Even as businesses transition to operating remotely, we understand that supply chain services must continue. Our team is here to support the shippers, carriers, freight-forwarders, and operators who must carry on during these trying times. Our reliable solutions will continue to support our customers requiring hazmat certification training.
Our self-paced online training and instructor-led webinars provide safe, travel-free options to complete your dangerous goods training from the comfort of your home.
We’re here to help with regulatory technical support Monday-Friday from 8:30 AM – 5:00 PM EDT at no cost to you.
Need help selecting the right online hazmat training course for your training needs? Our modal and multimodal courses combine lessons containing the latest regulatory information with interactive exercises and quizzes to facilitate compliance with regulatory training requirements. Call us at (844) 532-7634 / (609) 860-0300 or contact us online, and we’ll be glad to help you!
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