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EHS Training Assessment Time

As people return to work from vacations and summer hours, now is the time to make sure that all environmental health and safety (EHS) regulatory training for 2026 is either completed or scheduled to be. In this blog, we review common training/retraining needed for employees as required by federal and state agencies such as the Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT) and more. We have also included additional courses that are recommended as best practice.

Hazard Communication and Emergency Response

If new or different hazards are introduced, employees are assigned additional tasks, or there are other changes to workplace conditions, training on the following standards must be refreshed. Even if not required, conducting training sessions or safety talks to review these topics is recommended annually.

Biohazards

Employees working with, around, or entering labs with blood or other potentially infectious materials (OPIM), as well as those performing first aid functions must be trained prior to performing said duties and within 12 months of the previous OSHA Bloodborne Pathogens (BBP) Standard [29 CFR 1910.1030training.

Specialty/Emergency Equipment

Workers who have been trained to wear or use special and/or emergency equipment must receive annual training.

OSHA Hazardous Waste Operations and Emergency Response [29 CFR 1910.120] (HAZWOPER) trained emergency responders are required to attend a refresher course within 12 months of the previous training. For answers to What is HAZWOPER?, How do I know if I need training?, and more, please visit our HAZWOPER FAQ webpage.

Hazardous Waste Management

If employees are managing hazardous waste on-site, they must be trained on the federal Resource Conservation and Recovery Act (RCRA) [40 CFR parts 260 through 273] and/or state-specific rules (e.g., MA RCRA Training for Life Sciences [310 CMR 30], NY RCRA Training for Life Sciences [6 NYCRR 370-374 and 376]). This includes, but is not limited to, those operating equipment that generates waste in a satellite accumulation area (SAA), moving or managing waste to the main or central accumulation area (MAA/CAA), or for anyone responsible for inspecting waste containers at the point of generation or in an accumulation area. Training must occur within 90 days and at least annually.

Hazardous Material/Waste Shipping, Transport, and Documentation

Personnel who affect hazardous materials in transport, including those packaging, closing, marking or labeling hazmat, and filling out or signing shipping documentation (e.g., shipper’s declaration, hazardous waste manifest) are considered hazmat employees. They must attend Hazardous Materials Regulations (HMR) training per 49 CFR 172 Subpart H within 90 days of job assignment/hire and must be supervised during that period if untrained and performing regulated activities. Refresher training is required if regulations or duties change, or at a minimum, within three years.

If hazardous substances are shipped via rail, aircraft, or vessel, additional DOT training is required. When shipping via air using certain carriers and/or internationally, specific rules must be followed, and each have their own training requirements. Dangerous Goods Air Transport/Shipping training is required prior to use and under the circumstances that follow.

  • International Civil Aviation Organization (ICAO) Technical Instructions (TI) refreshers are needed at least every three years if non-IATA transporters are used
  • International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) re-training is required biennially when shipping via IATA carriers

The International Maritime Organization’s (IMO) International Maritime Dangerous Goods (IMDG) Code must be adhered to when shipping hazardous materials on vessels internationally. Training for these regulations follows the same pattern as DOT, initial within 90 days, and retraining at least every three years thereafter. 

Certain hazardous materials may be transported without full DOT training if following Materials of Trade (MOT) Exceptions [49 CFR 173.6]. In order to transport MOTs, specific provisions such as labeling and securing of the materials in transit must be followed. Employees must be aware of the hazards and that they are using an exception to the rule. Best management practice recommends implementation of a formal policy and, at a minimum, requiring that employees read it and sign an acknowledgement of understanding. For more information on the MOT exceptions, please review our Are You Transporting Hazardous Materials? blog.

If you need assistance determining which training your organization needs, or to develop and deliver EHS training, contact us! Many of the classes listed above can be completed anytime, anywhere, using any internet capable device. Visit our EHS Training & Professional Development webpage for more information on the courses we offer and to register.  

This blog was written by Kim E. Folger, Senior Training and Development Manager at Safety Partners.

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