Question:
Do we need special Department of Transportation (DOT) training for employees signing the regulated medical waste (RMW) manifest?
Answer:
When DOT training applies
According to the Department of Transportation (DOT), any person who prepares regulated medical waste (RMW) for transport or signs a medical waste manifest on behalf of the generator (i.e. your facility) is subject to DOT requirements and are considered "hazmat employees". 49 CFR 172 Subpart H describes the training requirements for these "hazmat employees".
Acceptable alternative training
Section 172.704(b) describes alternative training that may be used to satisfy the DOT training requirements and this includes OSHA Hazard Communication (HazCom) training. HazCom training is included in our OSHA training courses and covers things like identifying hazardous materials and remediating small and large spills. In short, OSHA HazCom training satisfies the DOT requirement for hazmat employee training.
References:
- 49 CFR 172 Subpart H Section 704(b)
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