Waste Management
Training Frequently Asked Questions 
Below are frequently asked questions regarding the training provided the Waste Management Program of the Army Institute of Public Health.

Training
Q:01. Who needs specialized Department of Defense transportation training (e.g. Transport of Biomedical Material Course training, Medical Waste Transport Course, Hazardous Waste Transport training)?
A:DoD Reg 4500.9-R, Part II, Chapter 204 requires personnel who sign shipping papers or manifests for hazardous materials attend specialized transportation training. Certifiers must attend and complete one of the DoD-approved certification training courses. Once training is successfully completed, the Supervisor or Activity Commander must appoint the Certifier in writing as the designated certifying official for their facility. The latest copy of DoD Reg 4500.9-R is at http://www.transcom.mil/j5/pt/dtrpartii.cfm. Handlers who do not sign shipping papers need only receive general awareness, function specific, safety, and security training as indicated in DoD Reg 4500.9-R, Part II, Chapter 204. This training must occur within 90 days of employment and be documented in the employees training record. Additionally, all Drivers of hazardous material must receive Driver’s training per 49 CFR 177.816. Supervisors must ensure employees receive the appropriate training and that all certifiers are formally trained and appointed in writing by their Supervisor or Activity Commander to sign shipping papers/manifests (as the Commander's representative), once they successfully complete the required training.
Q:02. Can Transport of Biomedical Material Course graduates train and certify other personnel to sign shipping papers (or manifests) for biomedical material or other hazardous commodities?
A:NO. DoD personnel who sign shipping papers (or manifests) for the transport of biomedical material (or other hazardous materials/waste) must personally attend formal training at one of the DoD-approved schools as specified and required in DoD Reg 4500.9-R, Part II, Chapter 204.
Q:03. Can personnel who successfully complete formal DoD-approved transportation training provide general awareness training to unit personnel?
A:Yes, a person who is knowledgeable of DoD, DOT, and other National and International training requirements can provide general awareness, function specific, safety, and security training at a Supervisory-level to hazardous material employees (handlers) within their unit. Handlers are personnel who maintain safe operations when transporting hazardous materials and proficiency in job specific responsibilities. Handlers include warehouse workers, aircraft load teams, pallet build-up personnel, and other individuals who routinely come into contact with hazardous materials but do not package, inspect, or certify. This training is appropriate for personnel who handle (Handlers), but do not sign shipping papers (or manifests).
Q:04. Who is responsible for ensuring personnel receive the appropriate training?
A:Each supervisor must ensure that their handlers and certifiers receive appropriate training on transportation requirements specific to their duties as required per DoD Reg 4500.9-R, Part II, Chapter 204 and meet National and International transportation requirements.
Q:05. How long do Hazardous Materials Employers have to train their HAZMAT employees?
A:Employers have 90 days to provide general awareness, function specific, safety, and security training. Untrained HAZMAT employees must be supervised until trained.
Q:06. What type of training do personnel who transport Hazardous Waste need?
A:Persons who only certify HW shipments may satisfy the requirement for training by successfully completing one of the following courses: (a) Hazardous Waste Management and Manifesting Course, offered by: USACE Professional Development Support Center ATTN: CEHR-P-RG (Registrar) Box 1600 Huntsville, AL 35807-4301 DSN: 760-7421, Commercial: 256 895-7421, FAX: 7469 Web address: http://www.hnd.usace.army.mil/ (b) Transportation of Hazardous Material (HM)/HW for DOD, offered by: DLA Training Center (DTC) P.O. Box 3990, East Broad Street, Building 11, Section 5 Columbus, OH 43216-5000 DSN: 850-5990, Commercial: 616 692-5990 Toll free: 800 458-7903 Web address: http://www.hr.dla.mil/trn.htm (c) A DoD-approved 2-week Defense Hazardous Materials Transport Course as specified in DoD Reg 4500.9-R, Part II, Chapter 204.
Q:07. For which commodities are personnel who successfully complete the PHC Transport of Biomedical Material Course certified?
A:Per DoD Reg 4500.9-R, personnel who certify biomedical material shipments (Category A infectious substances, biological substances Category B, biological products, regulated medical wastes, toxins, limited quantity of Class 3 material, Class 9, and related biomedical material) will receive certification training to safely and effectively ship biomedical material per National and International requirements.
Q:08. How does the Medical Waste Transport Course differ from the Transport of Biomedical Material Course?
A:The Medical Waste Transport (MWT) Course is intended for personnel who prepare and only package Medical Waste (RMW) for transport. Personnel at a DoD medical facility who are directly involved in packaging medical waste for pickup for Stericycle or who have the potential to package and transport medical waste across public roadways should take our Medical Waste Transport Course. Personnel who just generate or handle medical waste (but do not package medical waste for transport) are required to be trained in accordance with (IAW) employee worker safety standards identified in the Occupational Safety and Health Administration (OSHA) 29 CFR 1910.1030 Bloodborne Pathogen standards and HAZMAT employee training standards specified in the Department of Transportation (DOT) 49 CFR Part 172.704.
Q:09. How do OSHA and DOT training differ and how do the training standards compare to DoD requirements?
A:OSHA requires personnel with occupational exposure to be trained at the time of initial assignment to tasks where occupational exposure may take place and at least annually thereafter. The DOT in 49 CFR 172.704 requires Hazardous material employees to receive 4 categories of training --- General Awareness/Familiarization training, Function-specific training, Safety training, and Security Awareness training. Employers must conduct this training within 90 days of employment and then once every three years. NOTE: All drivers of hazardous materials must also receive Driver’s training per 49 CFR Part 177.816. DoD certifiers of biomedical material must additionally receive formal training per DoD Reg 4500.9-R, Part II, Chapter 204. DoD employers will need to determine which of their employees are "Handlers Only" and which employees are "Certifiers"/"Packers". The "Certifiers"/"Packers" are the ones who truly need the DoD certification training (e.g. Transport of Biomedical Material Course or Medical Waste Transport Course).
Q:10. Do contractors need DoD certification training?
A:Yes. DoD personnel (Civilian, Military, or Contractors) who package or prepare hazardous materials shipping papers or manifests for DoD transport (e.g. medical waste, infectious samples and specimens) need to be trained IAW DoD 4500.9-R, Part II, Chapter 204. Contractor companies who are hired under contract by the DoD for the sole purpose of picking up and transporting hazardous material, biomedical material, or wastes from a medical facility across public highways to a disposal facility (e.g. Stericycle) must comply with the specific requirements of their contract and ensure their personnel are trained per Federal, State, and local transportation requirements and requirements specified in their contracts.
Q:11. Where do I register?
A:DoD personnel may register for initial and refresher certification training as required by DoD Reg 4500.9-R, Defense Transportation Regulations, Part II, Chapter 204 online at the Public Health Command’s website following the link below: http://phc.amedd.army.mil/Pages/Training.aspx
Q:12. How can personnel request onsite training from the Army Institute of Public Health?
A: Personnel may request onsite training by completing the eForm at: https://usaphcapps.amedd.army.mil/TrainCon/eForm.aspx?Name=OnSiteTrng The completed form (once submitted) is automatically sent via email to the Army Institute of Public Health Hazardous and Medical Waste Program Training Team Leader for evaluation and a determination regarding the submitted request.
Q:13. Who pays for onsite training?
A:The requesting unit pays for the training. A Statement of Work (SOW) is first submitted to the requestor delineating costs for the requested training. Once reviewed and signed, then funding is transferred from the requesting unit to the Army Institute of Public Health for project execution.
Q:14. How often is certification training required?
A:Certification training (e.g. Transport of Biomedical Material Course, Medical Waste Transport Course) is required biennially (every two years or 24 months) per DoD Reg 4500.9-R, Defense Transportation Regulations, Part II, Chapter 204 and AFMAN 24-204, Attachment 25.
Q:15. Can personnel request an extension for recertification?
A:Yes, each Service focal point (Army, Air Force, Marine, Navy, DLA) may grant an extension not to exceed 60 calendar days during which eligible personnel must receive training. Personnel extended past their initial 60- day extension by a Service focal point (due to long-term tactical or contingency operations) may only certify hazardous materials moved according to tactical or contingency operations. Personnel who are on normal duty, must receive the appropriate training to certify shipments and comply with DoD Reg 4500.9-R, Part II, Chapter 204 and AFMAN 24-204, Attachment 25. Medical personnel requesting an extension for recertification of their biomedical material transport training may do so by contacting the Army Institute of Public Health (AIPH) Waste Management Program (WMP) Training Team Leader via electronic mail. The electronic mail should include the purpose of the email, date of initial training, and reason for the request. Once submitted, the AIPH HMWP Training Team leader will review the request and issue approval if appropriate.
Q:16. Did the Department of Transportation raise its penalty amount?
A:No. In FR Doc 2010-21759, the Department of Transportation states that “the maximum and minimum civil penalties for violations of the Federal hazardous material transportation law, 49 U.S.C. 5101 et seq., and violations of regulations issued pursuant to that law. Those maximum and minimum penalties were most recently adjusted on December 29, 2009 (74 FR 68701) to consider the effects of inflation since reauthorization of the Federal hazardous material transportation law in August 2005. We found that the inflation adjustment in the Federal Civil Penalties Inflation Adjustment Act (28 U.S.C. 2461 note) (the Act)--the change in the CPI-U over the prescribed period--was 12.5%, but that the Act limited the adjustment of the maximum and minimum civil penalties to 10%. These adjusted maximum and minimum civil penalties apply to any violation occurring on or after January 1, 2010. More recently, it has been called to our attention that we did not apply the ̏rounding" requirement in Section 5 of the Act in making adjustments to the minimum civil penalty amounts. Applying the 12.5% increase in the CPI-U to the $450 minimum penalty for a violation related to training produces an increase of $56.25, which would be rounded to $100--except for the limitation in the Act that the initial adjustment may not exceed 10%. Thus, the adjusted minimum penalty of $495 for a violation related to training was correct. However, when the $250 minimum penalty amount for other violations is increased by 12.5%, the result would be an increase of $31.25, which must be rounded to the nearest $100--or $0. Thus, we should have left the minimum civil penalty for other violations at $250. Accordingly, we are correcting this error in both Sec. 107.329 and Sec. 171.1(g). PHMSA does not believe that the improper $275 civil penalty amount has been used in any enforcement case arising out of violations that occurred on or after January 1, 2010, and we will continue to use the proper $250 amount in such enforcement cases that have arisen since that date.”
Q:17. Can personnel transport hazardous materials or waste in their POVs?
A:No, the use of POVs for transport of hazardous materials is prohibited. This is not referenced in the 49 CFR but it is stated in DoD 4500.9-R Chapter 204 Section B.3.a. which reads, "Use of POVs for transporting of HAZMAT and HW is prohibited."
Q:18. If I have questions about biomedical material transport or questions regarding the transport of hazardous materials, who should I contact?
A:DoD medical personnel who have questions regarding biomedical material transport or the transport of hazardous materials may contact the U.S. Army Public Health Command Army Institute of Public Health Waste Management Program at DSN 584-3651/(410) 436-3651 or submit a written request via email to: usachppmhmwp@amedd.army.mil.