General Safety, Cargo Security and HAZMAT Training for Transportation Intermediaries and 3PLs
(Relationship between DOT, OSHA, C-TPAT, TSA and industry requirements)

1. General Safety training: All U.S. employers have safety training and emergency action plan responsibilities under OSHA regulations. In a facility where dangerous chemicals are present, the OSHA responsibility overlaps with the DOT HAZMAT training responsibility, and so training should be combined, and provided to all employees who could potentially face health and injury risk from exposure to such dangerous materials. Select employees must also be provided with awareness-level first-responder training in preparation for a HAZMAT emergency. Note: In order to meet OSHA requirements, general safety training must include the particulars of the facility emergency action plans, which can easily be incorporated as an add-on module (either on-system or off-system) to standard GISTnet courses. GISTnet course T14u—Safe Handling of Cargo in Cargo Terminals and Distribution Facilities, meets this training requirement for workers in cargo terminals and distribution centers.
2. Security Awareness training: In 2003, the DOT added "security awareness" to the training requirement for any employee to be certified by an employer as a "HAZMAT employee." For companies and facilities which are certified under C-TPAT (a CBP program) or TAPA program requirements, or who must comply with a TSA security plan, there exist substantially overlapping security training requirements, the significant difference being that all or most employees require such training, not only "HAZMAT employees" as specified under DOT rules, which specifically provide that the DOT HAZMAT cargo security awareness training may be fulfilled by equivalent training conducted pursuant to another government or industry security programs. GISTnet course T13u—Cargo Security Awareness for Forwarders and Customs Brokers (C-TPAT, TSA, DOT & TAPA), addresses this training need.
3. Hazmat General Awareness training: Needed to be certified as a "HAZMAT employee." Also recommended for all transportation intermediary employees who assigned to customer service, cargo booking and cargo handling jobs who must be able to recognize HAZMAT, or possible HAZMAT, shipments for referral to a certified HAZMAT employee. Degree of training in hazmat awareness training may vary with job assignment (a shipper, responsible for classifying, packing, labeling, marking, documenting and certifying HAZMAT, will typically need more thorough training than a freight forwarder or customs broker who needs only to understand outer packaging, labeling, marking and documentation requirements, and how to determine varying requirements by transport mode, national rules and carrier restrictions. GISTnet offers several courses which can be used to meet this need depending on the depth of knowledge one needs in a particular job. Refer to course descriptions in the course catalog and roadmap for hazmat employee certification.
4. Hazmat Function-Specific training: This training must cover one's particular job responsibilities with respect to HAZMAT shipping, and so varies with job assignment. GISTnet offers function-specific training for air and ocean freight forwarders, customs brokers and employees performing cargo terminal and warehouse operational tasks. Refer to course descriptions in the course catelog and roadmap for hazmat employee certification.
5. Hazmat Security Plan training: Required only if an employer has a DOT HAZMAT cargo security plan, and then only for employees who have responsibilities under the plan. Because this training must be based on specific company plan, it is not included in any standard GISTnet course or course module, but an on-line module can be easily created by an employer to assign as needed together with a standard GISTnet course.
6. TSA Security training: May be required under IACSSP; if so, will be "need-to-know" as to specifics of IACSSP based on work in air cargo operations. Portions of needed training may be fulfilled by general purpose cargo security training. Refer to GISTnet course catalog for several IACSSP training courses.
7. TAPA security program training: For companies which have TAPA security programs in place, training pursuant plan is operationally needed. There is a significant training overlap with other cargo security training requirements (e.g., C-TPAT, DOT hazmat, IACSSP).
8. OSHA Safety training: OSHA has a variety of general and industry and/or job-function specific training "standards". With respect to dangerous chemicals in the workplace, OSHA Hazard Communication rules (29 CFR 1910.1200) apply, and, where there is a potential for accidental HAZMAT spills and other releases, thereby creating the need for an emergency response to protect employee health and safety, and waste disposal, HAZWOPER rules (29 CFR 1900.120) come into play. The DOT HAZMAT "general safety" training requirement, for employees in a cargo terminal or distribution facility, are effectively met by training otherwise required under OSHA rules, the difference being that OSHA rules require safety training for all employees exposed to a potential hazard, not just "HAZMAT employees" as defined by the DOT. GISTnet course T14u—Safe Handling of Cargo in Cargo Terminals and Distribution Facilities, meets this safety training requirement for workers in cargo terminals and distribution centers, exclusing forlkift safety training (see also GISTnet course T15u—OSHA Forklift Safety (Hard Surface Lift Trucks).
9. Limited OSHA safety training: For employees who themselves have no potential exposure to hazardous materials because they work in an office or other location where HAZMAT cargo is never present, unless there are other occupational standards applicable (e.g., construction, industrial truck operator, etc.), the otherwise applicable OSHA safety training requirements are typically limited to the office/facility emergency action plan ("EAP," including evacuation plan), and such things as avoiding electric shock, trip and fall hazards.