JUNE 2019 • FOGHORN 29 SAFETYMATTERS IMTRA COLORS 2016 Primary Use Secondary Use Blue Pantone 647 96C 54M 5Y 27K Pantone Cool Gray 7 20C 14M 12Y 40K Pantone Cool Gray 2 5C 3M 5Y 11K Black 0C 0M 0Y 100K Pantone 368 65C 0M 100Y 0K Pantone 629 36C 0M 9Y 0K The Trusted Source for Advanced LED Lighting NAVIGATION LIGHTS • DECK LIGHTING • ENGINE ROOM LIGHTS • SEARCHLIGHTS • CABIN LIGHTING 508.995.7000 www.imtra.com LED www.imtra.com Ferry vessels transporting HAZMAT are subject to requirements in 49 CFR Part 176, in fact, 49 CFR 176.88 expressly states that “the re- quirements in this subpart are appli- cable to transport vehicles containing hazardous materials being transported on board ferry vessels and are in addition to any prescribed elsewhere in this sub- chapter.” This includes the training re- quirements for HAZMAT employees in 49 CFR 172.700-704 and 176.13, as applicable. HAZMAT Employees So, who is a HAZMAT employee, and would therefore require training? The HAZMAT regulations in 49 CFR 171.8 define a HAZMAT employee as a person who is: “Employed on a full time, part time, or temporary basis by a hazmat employer and who in the course of such full time, part time or temporary employment directly affects hazardous materials transportation safety.” The definition also includes a provision for a person who is responsible for the safety of transporting hazardous materials. In addition, PHMSA issued a letter of interpretation in August 2013, in response to a request from the Maine Department of Transportation, which stated: “State ferry employees who position transport vehicles carrying hazmat to comply with § 176.83, or direct placement of such transport vehicles as required by § 176.89(a)(2), directly affect hazardous materials safety and bear responsibility for the safe trans- portation of hazardous materials. Such employees are ‘hazmat employees’ and are subject to the training requirements of § 172.700-704.” According to the Coast Guard blog post, “At a minimum, the captain of the ferry and the person directing stowage location for the vehicle on the ferry are directly responsible for HAZMAT transportation safety, are considered HAZMAT employees, and are thus subject to HAZMAT training require- ments.” Training Requirements According to 49 CFR 172.704, HAZMAT employees require training every three years. The training will cover the following areas: • General awareness and familiariza- tion with the HAZMAT regulations; • Function specific training based on how the individual interacts with HAZMAT on board the vessel; • Safety training to include emergency response, personnel protective measures and accident avoidance; and • Security training to include risk identification and security threat response. Each HAZMAT employer must create and retain a record of current training of each HAZMAT employee, which includes the preceding three years, for as long as that employee is