We will now step up on to our soapbox...
The U.S. D.O.T. - Research and
Special Programs Administration - The Frequency of Training
In 1996 the U.S. Competent Authority (RSPA) changed
its recurrent training requirement from 2 years to 3
years, except for U.S. Flag Air Carriers, who still
have a one-year requirement.
Granted, we may have what would appear to be a selfish
motive, but it is our experience, based upon conducting
many recurrent training programs, that the three-year
requirement is a failure.
Our experience has been, that in three years, most
of the people have forgotten the important subjects
that they previously learned. While we at R-A Specialists
use motivational techniques in our initial training
programs, admittedly, it has all worn off by the time
the three-year cycle comes to an end. Speaking to other
training organizations we find that they have similar
experiences. Even the training records become dusty
and are often misplaced after two years. Because re-training
obligations are off on a distant horizon, shippers,
forwarders, and carriers fail to train replacements
for trained employees who have left the company for
another job or have simply retired. In some rare cases,
training records presented to enforcement personnel,
actually represent employees who have left the company.
While the three-year cycle might work for a small company
with a limited product line of perhaps one or two dangerous
goods, and a stable work force, it simply does not work
for transportation companies, distributors, and shippers
of multiple classes of hazardous cargo.
While many good-citizen type companies recognize the
problem and train their personnel on a more frequent
basis, far more stay strictly within the law and complacency
What do we see on a daily basis as a result of this
- Damaged hazmat cargo due to truckers failing to
brace the cargo as required.
- Damaged hazmat cargo due to careless handling in
- Undeclared dangerous goods because no one considered
the hazard classification system.
- Unconcerned reaction to hazmat spills.
- Hiding of damaged packages because no one understood
the potential risks.
- Nonchalance, if you will, concerning paperwork requirements.
These are all serious problems. Some are caused by
two-hour training programs. Still others by the failure
of companies to correctly identify their "hazmat
employees". We see a tendency by transportation
companies to designate 2 or 3 employees as hazmat-"certified"
out of a group of 50 workers with the explanation that
the other employees do not handle the hazmats. How does
an untrained employee recognize dangerous goods that
he should not handle? Are trained personnel available
during all working hours?
The data that we have accumulated from training and
testing over 25 years clearly shows that employees score
higher after an initial training class. They did not
score very much lower when tested at two-year intervals.
But there is a significant drop off in test scores now
that we are well into the three-year training cycle.
We know this by virtue of our policy that when an attendee
fails a test we bring them back for additional tutoring
and a new test.
While the U.S. RSPA staff has accomplished a great
deal in providing training aids, services, and up-to-date
information via its website, the violations continue.
The staff at RSPA is hard working and dedicated. But,
perhaps its time to revisit the issue of recurrent training.
You are welcome to comment about this topic by e-mailing
We will print your comments in future newsletters.
Please keep the comments brief and let us know whether
you wish to be identified or not. But you must identify
yourself at least to R-A Specialists if you wish to
have your comments printed in future newsletters.
We all have responsibilities for safety in transportation.