RETHINKING TRAINING Managing Complex Hazmat Training in a Post-LMS Era By Melissa Powers Regulatory Compliance Analyst AQT Solutions powersm@aqtsolutions.com www.aqtsolutions.com August 28, 2015 Author Bio As AQT’s Regulatory Compliance Analyst, Melissa Powers has extensive experience utilizing ATMS for a variety of training management systems. As AirNet System’s Regulatory Compliance Coordinator for over 15 years, Melissa was responsible for managing an extensive dangerous goods training program, TSA security programs and an airport security program. Melissa is knowledgeable in areas of dangerous goods/hazmat and TSA compliance and the complexities surrounding these regulatory environments.
TRAINING RECORDS IN THE HAZMAT WORLD Hazmat employers in the U.S. must comply with complex recordkeeping requirements based on 49 CFR 172.704 (d) which dictates that employers must keep a hazmat employee’s current training records and those of the previous 3 years as long as the individual remains an employee. These records include the most recent completion dates, description of training materials, names and addresses of training providers, and finally a certification that the employee has been trained and tested. This is usually in the form of a standard “certificate of completion” that can be provided to the trainee but then is maintained by the employer. All of these records must be maintained during the period of employment and for 90 days after the employee is no longer employed. The employer must make this information available to the DOT upon request. If your company ships to, or from, the U.S. and follows the IATA DGR’s the same DOT recordkeeping rules apply. OSHA hazard communication and blood borne pathogen standards also require training and subsequent recordkeeping that employers maintain for inspector review. OSHA can expand into areas beyond hazmat that require extensive recordkeeping such as power industrial trucks in 29 CFR part 1910.178 where initial training is required along with subsequent training to determine the trainee possesses essential knowledge. Training must be instructional as well as practical and involves a final evaluation of the trainee. The recordkeeping requirements for power industrial training dictates the operator to record the date of training, date of evaluation and refresher training. The common theme running throughout all of these regulatory entities, whether it be DOT, TSA, or OSHA, is that training records must be retained and reproduced for inspectors. The reality is that a lot of companies rely on paper methods or spreadsheets to manage their training. Having a training management system offers the freedom to break away from these sometimes risky practices by electronically managing training courses and records. When paper records are the only method of tracking and retaining training information, managers are often unsure of where a trainee’s status actually stands; ATMS (Advanced Training Management System) allows for a centralized data repository with a summary of each trainee’s real time status, history and future training requirements. Companies that manage an extensive catalog of training with varying regulatory bodies across many modes of transport and geographic locations can especially benefit from the ability to centrally locate and manage all of their training courses. Our system is designed to build parameters surrounding each course based on the governing regulators’ requirements.
CONSOLIDATING RECORDKEEPING IN A SINGLE SYSTEM ATMS combines regulatory compliance training requirements into a single, integrated recordkeeping system which substantially reduces the possibility of missed or overlooked training requirements. Our system allows training records to be maintained within one centralized location across multiple regulatory agencies; completion dates and scores can be viewed for all training courses. ATMS can also be used to store and manage employee certifications and personal HR data and identifying information (STAs, SIDA badges, employee IDs, passports, etc.). It is essentially a one-stop shop for all training and recordkeeping data.
TRAINING HELPS PREVENT HAZMAT INCIDENTS The majority of transportation incidents involving hazardous materials are the result of human error; training is the best approach to incident prevention. The burden of maintaining training records between a small and large corporation is the same. Whether a company is large or small, they are faced with the
same challenge of maintaining safety and compliance within a complex regulatory environment. Smaller organizations tend to have less resources dedicated to tracking their employee training records. Those duties may be split among multiple personnel responsible for different groups of trainees, each using their own recordkeeping methods. Large corporations manage higher volumes of employee training and may have more resources dedicated to recordkeeping, but do not have a cohesive way to effectively manage their process. They also may be burdened with providing vendor/partner training across multiple geographic locations. Regardless of the size of an organization, there are common challenges that companies face when they are relying on manual processes. A training management system helps companies organize and issue their training materials, deliver the training, record, and store the required results and information. ATMS basically allows organizations to manage training and recordkeeping more efficiently, and be better prepared for regulatory audits.
GLOBAL MULTI-MODAL TRAINING COMPLIANCE It’s not necessarily easier. Hazmat training requirements in subpart H of part 172 apply to each mode of transportation. However, depending on the mode of transport, the carriers must follow their respective part within 49 CFR (air/highway/vessel/rail). There may be slight variations among the requirements on where training records are to be maintained and additional regulations that must be followed within each part. An air carrier for example would have to comply with 14 CFR parts 121 and 135 in addition to part 172 subpart H. Highway carriers that employ drivers need to ensure parts 390-397 are being followed. It can actually get pretty complicated when using multiple modes to transport hazardous materials. The U.S. government does provide an electronic code of federal regulations free of charge which makes it extremely easy to navigate around the regulations but that doesn’t necessarily make the recordkeeping aspect easier. Companies still need to comply with subpart H but also ensure they are not missing any nuances within their specific mode of transport. European carriers deal with separate regulations for mode of transport including RID, ADR, IMDG and IATA DGR’s and depending on mode of transport could be juggling all of these regulations or just some of them. The effectiveness of ATMS is it allows companies to manage the training requirements of each regulatory agency. Training is designed in the TMS based on regulatory oversights such as frequency and re-currency of each training curriculum. Because ATMS is built to manage regulatory compliance, it is designed to look at a multitude of factors that could affect the currency of training such as test scores and grace periods. A company that has to follow multiple regulations benefits from a system like ATMS because it can manage an unlimited number of training courses that each come with varying oversight and requirements.
HOW A TMS IMPROVES HAZMAT TRANSPORTATION ATMS offers efficiency and organization to every company conducting qualification-based training with regulatory based materials; it maximizes productive by eliminating human errors and valuable time from manual recordkeeping, filing, and updating spreadsheets. The system manages the entire training process from course set-up to scheduling resources (trainees, instructors, and devices such as classroom and CBT for eLearning), recordkeeping, and maintaining recurrent training. Automatic re-queuing and notifications allow peace of mind that trainees will not go past their training due dates. One of the many advantages between ATMS and a typical LMS is that ATMS provides unlimited training courses (from classroom to eLearning) without charging additional fees; an LMS will charge a fee for every course taken. Even for a small size company, the cost could be exorbitant if each employee has to take
multiple courses to complete their annual training requirements. Another advantage ATMS has over an LMS is that it is an integrated training system with a built in LMS to manage all eLearning content; companies will no longer have to pay for an LMS service! Whether a company decides to use ATMS installed on-site or in a hosted environment, the feasibility of the system provides plenty of options to meet all needs, as well as experiencing award winning customer service from AQT Solutions.
COMMON ERRORS A TMS CAN HELP AVOID Relying on manual recordkeeping process that allow for a lot of human error and simply not maintaining training and trainee information in one location. The reality is most companies have many different departments managing their training processes. So, you are not seeing simply one department that manages training for an entire company. These responsibilities are spread out over an organization and multiple managers which can create miscommunication and disorganization. ATMS allows all of these departments to essentially come together. A trainee exists once in the system but everyone can see where that employee stands in regards to all of their training records and information.
Organizations also run into pitfalls when trying to use only an LMS to manage their training. They may receive notifications of completion but the actual management of the trainee and all aspects surrounding their currency are not handled. Companies often purchase courses through an LMS provider but then have little control over the management of the courses or the billing for those courses. They are even charged by the LMS vendor for delivering courses that were developed and owned by the company. ATMS is a TMS with a built-in LMS, managing all training requirements for those in the regulated environment. ATMS goes beyond just completing an eLearning course and getting a notification by managing multiple training schedules, collecting grades on any type of training, handling vendor training they may be responsible for, manage training expiration dates for qualifications, handle recurrent training, and managing currency
CHOOSING THE BEST HAZMAT TRAINING WITH A SYSTEM IN MIND Purchase training courses from reputable companies that are members of their respective trade associations/groups. Understand employee job duties and ask for employee feedback on training. Employees are key indicators regarding effective training; after all they want to be confident at their job duties. It may be wise to review a course for effectiveness or ask others in peer groups for recommended courses. Courses are not given a seal of approval by government agencies so it is important that organizations understand the regulations and know what is required for proper training of their employees. ATMS provides a modern, integrated system that maintains accuracy and currency of training records that gives companies the confidence and assurance to be audit-ready and compliant.
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