According to 49 Code of Federal Regulations (CFR) personnel involved in the PREPARING, PACKAGING and SIGNING (certifying) shipping papers for the outgoing or incoming shipment of a hazardous material are required to have this training. If a company has a specific license, the USNRC and the Agreement States require the key personnel to maintain this certification.
I have noticed when performing the initial complementary review of a prospect’s Radiation Protection Program and discussing the need with them that it is often stated that it is included in their company HAZMAT training for selected site personnel. However, after further review of their records, the training was typically for common industrial hazards, such as, chemical hazards (flammables, corrosives and poisons). Radioactive materials may be mentioned but programs that I observed did not provide the step by step refresher training to personnel in the actual packaging and shipment of the specific radioactive materials, such as fixed industrial gauges, on their site.
Remember, the HAZMAT training is SITE specific and HAZARD specific. If one has a training certificate, the inspector simply asks, “Show me the curriculum that covers ALL of the hazards on your site”. In other words, one may need multiple training sessions to completely certify personnel.
At a minimum the syllabus needs to show that all hazards are covered. The training required is commensurate with the hazard. For example, in a previous company I was the RSO, when receiving radioactive wastes for treatment, the USDOT HAZMAT training was 40 hours to qualify the employees to receive the untreated wastes, do the preparation then ship the treated wastes to radioactive burial sites.
For shipping and receiving fixed industrial gauges, the employees first need the 8 – hour Authorized User training before the HAZMAT training. This is because the terminology, understanding the risk and how to use a survey meter are taught in the AU training.
The most common Category of personnel typically left out are the central shipping and receiving personnel. If they sign the shipping or receipt of hazardous materials, they need to be certified. For shipment via ground, this refresher training is required every three years. If shipment via air or Fedex, it is every two years.
If you have further questions, please feel free to call AEC or your regulator for more information.