From: Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM>
Subject: Re: [DCHAS-L] Documentation question
Date: Thu, 21 Jan 2021 15:06:27 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: MN2PR05MB70537A98E75FD4767F8CC95AADA19**At_Symbol_Here**MN2PR05MB7053.namprd05.prod.outlook.com
In-Reply-To <0f4601d6ef6f$459cf190$d0d6d4b0$**At_Symbol_Here**chemical-safety.com>


For OSHA, the publication linked bellow tells you what training records are required for each standard. The standards that require signatures are specific on what information is to be on the document and who’s signature is required.

 

I’m guessing that signature requirements vary between agencies. So is possible your inspector was drawing from a different standard.

 

https://www.osha.gov/Publications/osha2254.pdf

 

Thank you,

 

Yaritza Brinker

260.827.5402

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of NEAL LANGERMAN
Sent: Wednesday, January 20, 2021 4:00 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Documentation question

 

** External Email **

Jeff

On the specific point you highlight, we had an IATA inspection and produced sign in sheets that had a wet signature of each participant and a wet signature on the mandatory written test of each participant. The instructor wet-signed and dated the sign in. The inspector stated “Good. If you had not gotten actual (wet) signatures I would have cited you.”

 

That is really the underlying cause of my question.  To the best of my knowledge, we are in uncharted waters here and have no agency guidance.

 

NL

 

 

Stay healthy and stay safe – Get Vaccinated!

NEAL LANGERMAN, Ph.D.

5340 Caminito Cachorro

San Diego 92105

+1 (619) 990-4908

neal**At_Symbol_Here**chemical-safety.com

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Jeffrey Lewin
Sent: Wednesday, January 20, 2021 11:23 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Documentation question

 

Neal 

 

A follow up on DOT training record requirements:

 

Taken from:

 

HAZMAT TRANSPORTATIONTRAINING REQUIREMENTS An Overview of 49 CFR PARTS 172-173

 

[Bold emphasis is mine]

 

TRAINING RECORDS
Training records must be kept by the hazmat employer for each hazmat
employee, and must include the following:
• the hazmat employee’s name;
• the completion date of the most recent training;
• training materials used (copy, description, or location);
• the name and address of the hazmat trainer; and
certification that the hazmat employee has been trained and tested.
Training records must be retained for each hazmat employee for three
years from the date of the last training, and for 90 days after the
employee leaves.

 

On Wed, Jan 20, 2021 at 2:03 PM Jeffrey Lewin <jclewin**At_Symbol_Here**mtu.edu> wrote:

Neal, 

 

Similar to Monique, I've made a "self certification" form in the past listing the title of the seminar and date attended.  I've based this on our State regulators that do on-line webinars and encourage downloading and using their self certification form. 

 

However, that might not work for everything, especially DOT since it is my understanding that DOT training requires documented passing an examination/ quiz.

 

Jeff

 

 

 

On Wed, Jan 20, 2021 at 1:46 PM Monique Wilhelm <mwilhelm**At_Symbol_Here**umich.edu> wrote:

Hi Neal,

I have made a list of attendees and I signed to certify that they were
in attendance and keep it with the materials presented in place of the
normal attendance sheet that I would have the attendees sign.

Best,
_________________________________________________________
Monique Wilhelm
Lab Manager
CAS, Department of Chemistry & Biochemistry | The University of Michigan-Flint
303 E. Kearsley St | Room 572 MSB | Flint, MI | 48502-1950
NEW EMAIL ADDRESS: mwilhelm**At_Symbol_Here**umich.edu

On Wed, Jan 20, 2021 at 1:33 PM NEAL LANGERMAN <neal**At_Symbol_Here**chemical-safety.com> wrote:
>
> All:
> Happy Inauguration Day!
>
> When doing virtual training that requires legal documentation of
> attendance (DOT/EPA/OSHA) how do you document participation? In
> particular, how can this be done on MS Teams platform?
>
> Thank you.
>
> Neal
>
>
> ----------------------------------------------------------------------
> --------------
> Stay healthy and stay safe - Get Vaccinated!
>
> The information contained in this message is privileged and
> confidential and protected from disclosure. If the reader of this
> message is not the intended recipient, or an employee or agent
> responsible for delivering this message to the intended recipient, you
> are hereby notified that any dissemination, distribution or copying of
> this communication is strictly prohibited. If you have received this
> communication in error, please notify us immediately by replying to
> the message and deleting it from your computer.
>
> NEAL LANGERMAN, Ph.D.
> ADVANCED CHEMICAL SAFETY, Inc. (Retired)
> 5340 Caminito Cachorro
> SAN DIEGO CA 92105
> +1 (619) 990-4908
> www.chemical-safety.com
>
> ---
> For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
> Follow us on Twitter **At_Symbol_Here**acsdchas

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
Follow us on Twitter **At_Symbol_Here**acsdchas


 

--

Jeff Lewin

Director of Chemical Laboratory Operations

Research Integrity Office

Laboratory Operations

205 Lakeshore Center 

Michigan Technological University

 


 

--

Jeff Lewin

Director of Chemical Laboratory Operations

Research Integrity Office

Laboratory Operations

205 Lakeshore Center 

Michigan Technological University

 

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas




Electronic Transmission Confidentiality Notice

The information contained in this electronic transmission is private, confidential, the property of the sender, and intended for the use of the recipient(s), only. If you are not the addressee, any disclosure, copying, distribution or use of this information for any purpose is strictly prohibited. If you have received this information in error, please notify the sender, YBrinker**At_Symbol_Here**fele.com, immediately by e-mail and then delete this message. Thank you.
[FE.EN.1]

Previous post   |  Top of Page   |   Next post



The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to secretary@dchas.org.
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.