8.0 - security awareness

8.0 - SECURITY AWARENESS

1 | P a g e Hazardous Materials Regulations 8.0 Security Awareness

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Table of Contents

Introduction ......................................................................................................................................................................2

Regulated Functions.......................................................................................................................................................3

Mitigation of the Security Threats ............................................................................................................................5

Personnel ............................................................................................................................................................7

Hazardous Materials and Package Control.............................................................................................7

En Route Security .............................................................................................................................................8

Technical Innovations .....................................................................................................................................8

Management Prerogatives ...........................................................................................................................9

Communications...............................................................................................................................................9

Emergency Response ................................................................................................................................... 10

Readjustments Based upon Current Conditions............................................................................... 10

Security Awareness ..................................................................................................................................................... 11

Security Plan (§172.802) ........................................................................................................................................... 12

Components of a Security Plan................................................................................................................................ 14

Training Requirements............................................................................................................................................... 20

Security Plan Implementation ................................................................................................................................. 21

Security Plan Maintenance ....................................................................................................................................... 22

Additional Planning Requirements - Rail ............................................................................................................ 23


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Security Awareness Introduction

Introduction

Title

NARRATION: Security awareness training provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. It also specifies the materials and amounts for which a security plan is required. This training also includes information on how to recognize and respond to possible security threats. New hazmat employees must receive the security awareness training within 90 days after employment.

Given the heightened specter of terrorism, the security of hazardous materials shipments has become a priority for carriers, shippers, consignees, emergency responders, and government officials.


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Functions

NARRATION: According to the HMR, Transportation or transport means the movement of property and loading, unloading, or storage incidental to that movement. Transportation of a hazardous material in commerce begins when a carrier takes physical possession of the hazardous material for the purpose of transporting it and continues until the package containing the hazardous material is delivered to the destination indicated on a shipping document, or package marking, for example. Take a look at the diagram displayed in the image. Loading, unloading, or storage incidental to movement of hazmat takes place during transit. Let's review what happens before a hazardous material is offered for transportation or transported. Pre-transportation function means a function specified in the HMR that is required to assure the safe transportation of a hazardous material in commerce, including classification of hazardous materials, selecting a hazmat packaging, hazard communication, documents preparation, certification, loading, blocking, and bracing, segregation. See §171.1 for the complete definition. Packagings must be qualified for use in the transportation of hazardous materials in commerce.


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Regulated Functions NARRATION: We discussed that the Hazardous Materials Regulations apply to packagings represented as qualified for use in the transportation of hazardous materials in commerce and to pre-transportation and transportation functions.

The HMR are designed to ensure that hazardous materials are packaged and handled safely during transportation, thus minimizing the possibility of their release should an incident occur, and to effectively communicate to carriers, transportation workers, and emergency responders the hazards of the materials being transported.

What happens if any of these regulated functions designed to minimize threats to life, property, and the environment are sabotaged or negatively impacted by someone’s actions for criminal or terrorist acts?


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Security Introduction NARRATION: Everyone who is involved in the transportation of hazardous materials should be aware of security issues associated with such transportation. All hazmat employees should know that certain people may ask questions or seek to acquire information that could be used to target hazardous materials for criminal or terrorist acts. Points in the hazmat transportation chain where security risk may exist must be identified to reduce the security risk.


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Tabs Interaction NARRATION: The risk control points can vary widely, depending on the quantities of hazmat transported, who handles the materials, the routes used, and where and when the hazmat is handled. To reduce or eliminate security threats, the following areas must be evaluated:

• Personnel; • Hazardous materials and

package control;

• En route security; • Technical innovations; • Management prerogatives; • Communications; • Emergency Response; • and Readjustment based

upon current conditions

Before moving to the next slide, please review the following examples.


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Examples: Personnel

Examples: HM and Package Control

NARRATION: Addressing security issues with personnel may include:

• Background Checks • Licensing • Adequate Training.

The security of facilities and equipment may include installation of adequate lighting, locks, or security systems.


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Examples: En Route Security

Examples: Technical Innovations

NARRATION: Avoidance of tunnels and high population centers are effective measures to ensure en route security. Use of appropriate access or satellite tracking and surveillance systems are valuable technical innovations that should be considered to reduce security threats.


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Examples: Management Prerogatives

Examples: Communications

NARRATION: A decision to start fingerprinting applicants during employment process may have an impactful security outcome.

Use of cell phones is a useful communication tool to reach all key personnel, as well as risk communications for public, and immediate reporting of suspicious activity or thefts to appropriate authorities.


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Examples: Emergency Response

Examples: Readjustments Based upon Current Conditions

NARRATION: Emergency response protocols may have to be reviewed to ensure the adequacy of training and resources for response to terrorist-type incidents.

Security threats may have to be reevaluated due to the heightened security after initial terrorist attacks or in accordance with threat levels that may have been established by appropriate authorities.


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Security Awareness

NARRATION: All parties involved in the hazardous materials transport chain should be aware of potential sabotage or other actions that could be directed at their operations. Hazardous materials in transit are uniquely vulnerable to theft or attack. To assure public safety, shippers and carriers must take reasonable measures to plan for and implement procedures to prevent unauthorized persons from taking control of or attacking hazardous materials shipments. In addition, a security plan that conforms to the requirements of the HMR in §172.800 must be developed and implemented when certain materials in specific quantities are offered for transportation in commerce or transported in commerce. The security plan prioritizes the security risk control points based on the degree of vulnerability and potential impact. The plan also outlines potential preventive and control actions based on the ability to reduce risk and the resources available. We will review the regulations pertinent to security plans next.


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Security Plans Outline

NARRATION: The requirements to develop and implement written transportation security plans to assure the security of hazardous materials shipments are outlined in Subpart 'I' of Part 172. Security plans must be developed and implemented to address security risks related to the transportation of certain hazardous materials.

As part of the transportation security risk assessment, in addition to the potential threats posed by the material, a security plan must focus on personnel, facility, and en route security issues, as a minimum.

Also, the security plan must include a training plan and those responsible for the security plan development and implementation.

We will review all requirements next.

The security plan, including the transportation security risk assessment developed, must be retained for as long as it remains in effect.


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Materials and Quantities (§172.800)

NARRATION: Each person who offers for transportation in commerce or transports in commerce one or more of the following hazardous materials must develop and adhere to a transportation security plan that is completed in accordance with Subpart 'I' of Part 172.

The full list of such materials is displayed in the image.

These materials include explosives, radioactive materials, materials poisonous by inhalation in Hazard Zone A; and select infectious substances identified by CDC as materials with the potential to have serious consequences for human health and safety if used illegitimately.

Also, this list includes shipments of liquids, gases, or solids in bulk packagings with specific capacities and shipments that require placarding.


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Security Plan (§172.802)

Components of a Security Plan (§172.802)

NARRATION: For shipments of the hazardous materials listed in §172.800, the security plan must include an assessment of transportation security risks and appropriate measures to address the assessed risks.

An assessment must include:

• facilities security, • personnel security, • unauthorized access, • and en route security.

In addition, a security plan must include the names and titles of the responsible officials and the security plan implementation process.

As part of an assessment of possible transportation security risks for hazmat shipments, the security plan must also include site-specific or location-specific risks associated with facilities at which the hazardous materials are prepared for transportation, stored, or unloaded incidental to movement.


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NARRATION: The security plan must include measures to confirm information provided by job applicants hired for positions that involve access to and handling of the hazardous materials covered by the security plan. Such confirmation system must be consistent with applicable Federal and State laws and requirements concerning employment practices and individual privacy.

The plan must include measures to address the risk of unauthorized persons gaining access to the hazardous materials covered by the plan or transport equipment being prepared for transportation of hazardous materials covered by the plan.


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Unauthorized Access Measures

NARRATION: Unauthorized access to the hazardous materials or associated transport equipment is a serious security threat.

Identity verification is an important measure to prevent such unauthorized access. For example, all employees must display identification cards or badges when on company premises or prior to releasing or loading hazmat, ask the driver for a commercial driver’s license for comparison with information provided by the carrier

The security measures to prevent an unauthorized access at the facilities where hazmat is loaded, unloaded, or stored can be as follows:

• Restricted availability of hazmat-related information,

• Hazmat is secured in locked buildings or fenced areas and access is restricted to a single entry or gate;

• Security guards, additional lights, alarm system, or surveillance cameras

To prevent an unauthorized access while hazmat is in transit, the following security measures could be implemented:

• Secured valves, manways, and other fixtures on transportation equipment;

• Tamper-resistant or tamper-evident seals and locks on cargo compartment openings.

And remember to report any suspicious incidents or individuals to local law enforcement officials or the FBI.


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NARRATION: The plan must include measures to address the assessed security risks of shipments of hazardous materials covered by the security plan en route from origin to destination, including shipments stored incidental to movement.


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Unauthorized Access Measures

NARRATION: Hazardous materials en route from origin to destination, including shipments stored incidental to movement, are uniquely vulnerable to theft or attack.

Information exchange with local law enforcement officials, emergency responders, or other public safety agencies helps to stay informed about current threats and trends (for example, regions or trailer types with a higher frequency of theft)

Select en route security measures are as follows:

• Conduct a security pre-transportation inspection to identify any unknown objects, or items, that do not belong, and re-inspect a transport vehicle after every stop;

• Stay on the identified preferred or alternative route;

• Minimize stops en route; if you must stop, select location with adequate lighting on well-traveled roads;

• Maintain regular communication with dispatchers or terminals;

• Never discuss hazardous materials shipments with any unauthorized, or unidentified individuals, outside the company, including load content, loading and unloading schedules, and routing information.

And remember to report any suspicious incidents or individuals to local law enforcement officials or the FBI.


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Components of a Security Plan (§172.802) Continued

NARRATION: We already discussed that for shipments of the hazardous materials listed in §172.800, the security plan must include an assessment of transportation security risks (including site-specific or location-specific risks associated with facilities, personnel security, unauthorized access, and en route security)

In addition, it must include responsible officials and the security plan implementation process, which include the following:

• Identification by job title of the senior management official responsible for overall development and implementation of the security plan,

• Security duties for each position or department that is responsible for implementing the plan (or a portion of the plan), and

• The process of notifying employees when specific elements of the security plan must be implemented

• And a plan for training hazmat employees in accordance with §172.704 (a)(4) - security awareness training and §172.704(a)(5) - in-depth security training.


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Components - Training

NARRATION: Because many hazardous materials transported in commerce may potentially be used as weapons of mass destruction or weapons of convenience, it is critical to the assurance of public safety that training for persons who offer and transport hazardous materials in commerce include a security component.

Every hazmat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats. New hazmat employees must receive the security awareness training required by the HMR within 90 days after employment. This training module meets this training requirement.

Hazmat employees of persons required to have a security plan must be trained in the plan’s specifics in addition to security awareness training that is required for all hazmat employees. In-depth security training provides training in the plan’s specifics and includes company security objectives, organizational security structure, specific security procedures, specific security duties and responsibilities for each employee, and specific action to be taken by each employee in the event of a security breach.

The hazmat employees training plan must be included in the security plan for shipments of the hazardous materials listed in §172.800.


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Other Federal Agencies

NARRATION: Once an assessment of transportation security risks for shipments of the hazardous materials listed in §172.800 is completed, appropriate measures to address the assessed risks must be identified.

A company should implement a plan that is appropriate to its individual circumstances, considering the types and amounts of hazardous materials shipped or transported, and the modes used for transportation.

Risk Management Self-Evaluation Framework (RMSEF) provides a structured way of assessing risk and helping hone practical, common-sense knowledge to reduce risks even further. You can view the tool on the DOT website or by clicking the identified text box.

To avoid unnecessary duplication of security requirements, security plans that conform to regulations, standards, protocols, or guidelines issued by other Federal agencies, international organizations, or industry organizations may be used to satisfy the security plan requirements outlined in Subpart 'I' of Part 172.


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Maintenance

NARRATION: So far, we've discussed the components of a security plan.

Now, we will review the aspects of the security plan maintenance outlined in the HMR:

• Security Plan Review and Hazmat Employees Training,

• Security Plan Availability Restrictions, and recordkeeping.

The security plan must be reviewed at least annually and revised or updated, as necessary, to reflect changing circumstances.

When the security plan is updated or revised, all employees responsible for implementing it must be notified. If the security plan is revised during the three-year recurrent training cycle, then hazmat employees must be trained in the plan’s specifics within 90 days of implementation of the revised plan.

Consistent with personnel security clearance or background investigation restrictions and a demonstrated need to know, the most recent version of the security plan must be available (in totality or portions) to the employees who are responsible for implementing it.

All copies of the security plan must be maintained. The security plan must be made available upon request, at a reasonable time and location, to an authorized official of the Department of Transportation or the Department of Homeland Security.


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Additional Planning Requirements - Rail

NARRATION: Each rail carrier transporting in commerce one or more of the following materials is subject to the additional safety and security planning requirements:

• More than 2,268 kg (5,000 lbs.) in a single carload of a Division 1.1, 1.2 or 1.3 explosive,

• Any quantity of a material poisonous by inhalation in a single bulk packaging

• A highway route-controlled quantity of a Class 7 (radioactive) material, as defined in §173.403,

• A high-hazard flammable train (HHFT) as defined in §171.8,

• Any quantity of UN1972 (Methane, refrigerated liquid or Natural gas, refrigerated liquid) when transported in a rail tank car.

There are additional requirements, including rail route analysis, alternative route analysis, commodity data collection, outlined in §172.820 of the HMR.

If you are subject to the security plan requirements by rail, you must develop and implement a plan that is inclusive of the elements outlined in §172.820.

8.0 - security awareness

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