Hazardous Materials Transportation Security Plan

Hazardous Materials Transportation Security Plans are required for any person, firm,

company, partnership, or corporation that ships, offers, or transports any of the following

types or quantities of hazardous materials. Please () the categories that apply to

your company.

A quantity of hazardous materials that requires placarding.

Highway route controlled hazardous materials.

More than 25 kg (55 pounds) of 1.1, 1.2, or 1.3 explosives

Packages greater than 1 liter of a material that is poisonous by inhalation in Hazard Zone A.

A shipment of a quantity of hazardous materials in bulk packaging with a capacity equal to or greater than 13,248 L (3500 gallons) for liquids or 13.24 cubic meters (468 cubic feet) for solids

A shipment of non-bulk packages of more than 2,268 kg (5,000 pounds) or more of one class of hazardous materials for which placarding would be required.

A select agent or toxin regulated by the Centers for Disease Control and Prevention under 42 CFR part 73.

If your company performs any of the above listed activities, you must prepare and implement a transportation security plan, and train your hazard employees on the plan and its implementations. If you do not, no security plan is required, but you must offer security awareness training to all of your hazmat employees.

By December 22, 2003 you must train each hazmat employee on your security plan. The training must include company security objectives, specific security procedures, employee responsibilities, actions to take in case of a security problem, and your organizational security structure.

All hazmat employers must provide security awareness training to their hazmat employees. Awareness training must include how to recognize and respond to security threats, and the risks associated with hazmat transportation. New employees must receive security awareness training within 90 days of employment, as part of their basic hazardous materials training.

Security Plan

Company

Company Name has created the Security Plan to conform with the United Sates Department of Transportation (USDOT) hazardous materials regulations in 49 CFR Part 172, subpart I. All employees shall comply with the provisions and requirements of this plan.

All hazardous materials employees of this company with access to or control over hazardous materials must review this plan, and act according to company policy and the regulations to implement the plan. Any employee with questions about the plan or their duties and responsibilities to implement the plan should immediately contact management.

Company Name has conducted a vulnerability assessment and ranking of the hazardous materials shipped or transported by this company. This assessment was done using the USDOT assessment tools and is attached. It is based on the level of hazard presented by the material, the type of packaging we use (cargo tanks, portable tanks, drums, etc.) the amount we ship/transport, and the routes we use. The materials we ship/carry are listed below in order of the hazard they present in transportation:

1.______

2.______

3.______

4.______

5.______

6.______

When national Homeland Security Alert levels rise above normal levels, the Company will implement additional security measures. These will include additional security at our facilities, and additional measures for En-Route Security. These measures will include:

ORANGE Level High Risk

1.______

2.______

3.______

RED Level Severe Risk

1.______

2.______

3.______

All drivers and other employees with access to or control over these materials must implement the provisions of this security plan.

Transportation Security Risk Assessment

A hazmat transportation security plan must include an assessment of possible security risks for shipments of the materials listed in 49 CFR 172. 800. Factors that should be considered in your risk assessment include the types of hazardous materials you transport or ship, the quantity of hazardous material shipped or carried, the geographic area you operate in, and the mode(s) of transport used. The USDOT has a risk assessment tolls available on its web site at: and on its hazmat security training program. The list below includes materials frequently transported petroleum marketers. Use the tools provided in the USDOT materials to add any other materials that your company ships or transports.

Vulnerability Assessment

Assessing risk is the first step in developing an effective hazardous material security program. It is recommended that you use this guided assessment tool and the hazard class table found in the section 173.2a of the hazardous Materials Regulations (HMR) to conduct a self-evaluation of the materials that you store or carry. You can then use this risk assessment to plan your risk reduction strategy.

List all the hazardous materials that you transport or store.

Hazardous Material:

Now go to the next steps, ranking the hazard levels of each material, and then exposure risks to the material in transport.

Transportation Security Risk Assessment, cont.

Rank the potential hazards to persons or property presented by each material you ship or transport. The hazard precedence listing and table in 49 CFR 173.2a, or a materials hazard class/division and packing group can be used. In the example below, gasoline is ranked as a greater hazard than kerosene because gasoline is a packing group II medium hazard, class 3 flammable liquid, and kerosene is a packing group III low hazard material.

Next, determine the potential exposure to your hazardous material. Factors to consider include number of shipments, routes taken, shipment in bulk or non-bulk packaging, and the items listed below.

Vulnerability Assessment Ranking

Rank each hazard on a scale from 1 to 5 (1 = most hazardous)

Consider: flammability, explosivity, toxicity, vapor pressure, reactivity, corrosivity

Rank the exposure potential or accessibility of each of the hazards on a scale from 1 to 5 (1 = most likely to explode)

Consider: predictability of shipments, proximity to public events, volume, population, densities, proximity to significant landmarks, number and frequency of trips, stopping/refueling points, trip distances, environmentalconditions

Hazardous
Material / Hazardous
(1 = most hazardous)
1 2 3 4 5 / Exposure
(1 = most likely to explode)
1 2 3 4 5
Ethanol /  / 
Fuel oil /  / 
Gasoline /  / 
Kerosene /  / 
Propane /  / 

Now go to the final step of the vulnerability assessment, hazard ranking.

Transportation Security Risk Assessment, cont.

The final ranking of your materials will indicate those materials that should get the highest priority in your security planning. All materials covered by the security plan must be considered, and special emphasis should be given to

those materials that present the greatest security hazard.

Vulnerability Assessment Final Ranking

This is ranking of the hazardous materials that you deal with. The materials with the lowest numbers should be given the highest priority in planning your risk reduction strategy. All items that

rank with a value under 3 should be given immediate attention.

Next use the Facility Security Checklist, also found in the Library, to help with your security planning.

Hazardous Material / Hazardous
(1 = most hazardous) / Exposure
(1 = Most likely exposed) / Final Ranking
Propane / 1 / 3 / 4
Ethanol / 2 / 3 / 5
Gasoline / 2 / 3 / 5
Fuel oil / 3 / 3 / 6
Kerosene / 3 / 3 / 6

Personnel Security

Company Name will conduct background checks on all employees with access to the hazardous materials covered by this security plan. Company drivers holding a Commercial Drivers License with a hazardous materials endorsement must undergo a background record check that conforms to the requirements of the Transportation

Security Administration (TSA) and USDOT. This company will use the checklists in this program and other methods relevant to the operations of this company to comply with the personnel security requirements.

1. All applicants hired for jobs that allow access to or handling of the hazardous materials covered by this plan will undergo background checks consistent with the requirements of the USDOT and the TSA.

2. This company will comply with all relevant Federal, State, and Local laws concerning employment practices and individual privacy.

3. This company will use the Personnel Security Checklist in this plan and other appropriate tools as guides for conducting background checks on covered employees.

4. All persons hired or employed as CDL hazardous materials drivers shall submit fingerprints and in all ways conform to the requirements of the USDOT, TSA, and State Drivers License Agency for background checks on hazmat drivers.

5. All persons hired for these hazmat positions shall review the parts of the security plan relevant to their jobs, and implement these plans as directed by management.

6. All new hazmat employees will receive security awareness training within 90 days of the date they became hazmat employees of this company.

7. All hazmat employees with access to the covered hazardous materials will received in-depth security training in a manner consistent with the requirements of the USDOT regulations.

8. No hazmat driver employee will pickup hitchhikers or transport any unauthorized persons in a company commercial vehicle.

9. All employees of this company will carry company issued identification documents and present them when required.

10. All employees shall report any observed or suspected security problems or situations to company management immediately.

Personnel Security

Personnel security includes 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. Hazmat employees, who do not have access to the hazardous

material covered by the security rule, do not need to be included in security planning.

All efforts to confirm information provided by employees must be consistent with

applicable Federal and State laws concerning employment practices and individual

privacy. You are not required to do background checks on current employees, except

that drivers with Commercial Drivers Licenses (CDL) with hazmat endorsements will

undergo background checks when renewing the hazmat endorsements.

Drivers with CDL' s with hazmat endorsements are required by the Transportation

Security Administration (TSA) to undergo background record checks to renew their

hazmat endorsement. Drivers that do not pass the TSA background check will lose their

hazmat endorsement, but not their CDL. The following check list can be used for driver

and non-driver hazmat employees.

 /

Unexplained gaps in employment

 / Frequent job changes
 / Check all names used by the applicant
 / Type of military discharge
 / Citizenship
 / Present and prior residence information
 / Personal references
 / Criminal history
 / Valid CDL with Hazmat endorsement
 / Verify US citizenship for all employees
 / For non-US citizens, verify that all immigration papers are on file and properly documented
 / Include fingerprints and photos in the personnel file
 / Conduct interviews with potential employee
 / Use the interview to appraise personality, character, motivation, honesty, integrity, and reliability
 / Report any suspicious information to your company’s security department

Hazmat Driver Security Checklist

Question / Response / Comments
Driver Name and DOB
Date Hired
Drivers License Number & State of Issuance
Drivers License Class / A B C D
Hazmat Endorsement? / Y or N
TSA Background Check Completed? / Y or N / DATE / / /
Completed Driver Qualification File? / Y or N
Current Drivers License Record in DQ File? / Y or N
Confirm US Citizenship? / Y or N
Non-US Citizen, All Immigration Documents OK? / Y or N or N/A
Driver Trained on Security Plan? / Y or N / DATE / / /
Security Awareness Training? / Y or N / DATE / / /
Driver Hazmat Trained per 49 CFR 172 subpart H? / Y or N / DATE / / /

Non-Driver Hazmat Employee Security Checklist

Does employee handle or have access to hazmat? / Y or N If no, security plan training not required.
Employee Name and DOB
Any other names or aliases?
Date hired
Current Address
Previous Address
Background Check Completed? / Y or N / DATE / / /
Confirm US Citizenship? / Y or N
Non-US Citizen Immigration Documents OK? / Y or N or N/A
Employee Trained on Security Plan? / Y or N / DATE / / /
Security Awareness Training? / Y or N / DATE / / /
Employee Hazmat Trained per 49 CFR 172 subpart H? / Y or N / DATE / / /

Facility Security and Unauthorized Access

Company Name prohibits unauthorized persons to have access to critical areas where hazardous materials are stored or hazardous materials vehicles are parked. For the purpose of this plan, an unauthorized person is any person not employed by the company, the general public, and drivers or personnel from other companies. Unauthorized persons also include company employees not specifically authorized by management to have access to or handle the covered hazardous materials.

All company employees are charged with implementing the facility security section of this plan. Any breaches of security must be reported to management immediately. This company will use the checklists included in this plan and any other documents provided by management to ensure that unauthorized persons have no access to critical buildings, storage tanks, or transport vehicles.

1. Management assigns as the person in charge of security for

this company (facility). is assigned as backup security

coordinator.

2. This company conducts security awareness training for all hazardous materials

employees.

3. This company designates as security or controlled access

zones.

4. No unauthorized person is allowed in the controlled access zones.

5. All employees shall immediately report any unauthorized persons in controlled

access zones to the company security coordinator or to the police.

6. All buildings containing hazardous materials shall be locked or otherwise

secured.

7. All storage tanks shall have locks or other secure devices.

8. All hazardous materials vehicles shall be locked.

9. All hazardous materials power units or trucks shall have keys removed and

kept in authorized areas.

10. All visitors shall check in with management.

11. All delivery or pick-up drivers from other companies must remain in

designated areas while waiting for their trucks to be loaded or unloaded.

12. Company staff will examine and record credentials of all persons picking up

hazardous materials from this facility.

13. Company staff will record the license plate numbers of all trucks or trailers

picking up hazardous materials from this facility.

14. All fences, locks, lighting and securement devices will be regularly inspected,

and any defects noted shall be reported to management.

15. Any attempt at unauthorized entry, vandalism, or suspicious situations shall be

immediately reported to company security officials.

Facility & Vehicle Security Unauthorized Access

Your security plan must include methods to prevent unauthorized persons from gaining access to your materials or transport vehicles. An unauthorized person is anyone not authorized by the shipper or carrier to have access to hazardous materials vehicles or products. Each person required to have a security plan needs to define who unauthorized persons are for their facilities. These persons may include non-employees or employees that have no job need for access to the covered hazardous materials.

The following checklists can be used to evaluate your facility security. As facility types and location differ, customize the list to reflect your specific security areas of concern.

Question

/

Response

/

Action

1. What are your critical hazardous materials areas?
2. How does your security or operation change when national security alert levels are increased?
3. What police/fire/emergency medical agencies serve your facility and what are their telephone numbers?
4. Is there a list persons authorized to access the critical areas? Who has
the list?
5. How are unauthorized persons restricted from the area?
6. How many points of access are there to the facility?
7. Are hazmat storage tank values locked and sealed? /

Yes No

8. How often are the facility grounds, buildings, and equipment checked for security breaches?
9. Are all entries to your facility recorded?
10. Are you checking credentials and monitoring drivers from other companies making deliveries or pick-ups at your facility? / Yes No
11. How are vehicles with hazardous materials secured?
12. Do you record driver and vehicle information for hazmat shipments from your facility? /

Yes No

13. Are there specific procedures for closing and locking up the facility? / Yes No
14. Is there an alarm system on the tanks or storage areas of the facility? / Yes No
15. Is the alarm system tested? / Yes No
16. Are cameras used to monitor the facility? / Yes no
17. Are security personnel used to monitor the facility? / Yes No
18. Is there adequate lighting for the facility grounds? / Yes No

Facility Security Checklist 2

Question / Response / Action
19. Is there a fence or similar barrier around the perimeter of the facility? / Yes No
20. Is the barrier in good repair? / Yes No
21. How easy would it be to breach the barrier?
22. When was the last time that locks were changed?
23. Who has the keys to these locks?
24. Is the facility security in compliance with all federal, state, and local laws and regulations? / Yes No
25. Are security logs kept? / Yes No

En-Route Security

requires all drivers, dispatchers and other employees comply with company policy on En-Route Security. All employees shall follow policies and regulations on hazmat vehicle attendance, parking, and routing. All dispatchers, drivers, and driver helpers shall be trained in the requirements of the USDOT regulations concerning unauthorized passengers, and the hazmat driving, parking, attendance, and routing rules.

Company sales staff and supervisors shall not accept hazardous materials orders from unknown persons or business’ until the legitimacy of that new customer has been established. Sales staff shall get specific instructions on delivery locations and suggested routes from customers.

No driver or sales person shall deliver hazardous materials to unknown persons or suspicious or unusual locations. All drivers will immediately report suspicious delivery locations to management, and defer deliveries until the situation has been evaluated by management. The Company will use the checklist included in this plan and other available tools to ensure En-Route Security.