Question of the Week: When do I need a Security Plan?
Q. When do I need a hazmat security plan? Do I need a different plan for each placarded shipment?
A. Since 2003, the Department of Transportation has required some hazmat shippers and carriers to create security plans under 49 CFR Part 172 Subpart I. These plans are to ensure that high-hazard shipments are protected from malicious misuse, sabotage, and diversion, whereas the traditional hazmat regulations are intended to prevent and mitigate accidents.
During the early years of this program, a single outgoing shipment of a placarded load of hazardous materials required a facility to institute a security plan. This one-size-fits-all hazard classes standard covered many shippers and carriers whose activities did not pose a significant security risk.
In 2010 (75 FR 10974), the DOT calibrated the security plan requirements to apply to fewer shipments. Consequently, fewer businesses need to create and maintain security plans.
Some materials are always dangerous, so any quantity of the following types of hazardous material require a security plan:
- Division 1.1, 1.2, or 1.3 explosives;
- A material that is poisonous by inhalation (PIH);
- Organic peroxides, Type B, liquid or solid, temperature-controlled;
- Select agents or toxins regulated by the Centers for Disease Control and Prevention; or
- Highway route controlled quantities of other high-consequence Class 7 radioactive materials.
[49 CFR 172.800(b)(1), (5), (11), (13), and (15)]
Less dangerous materials are less regulated, so a placardable amount of the following hazardous material requires a security plan, but smaller quantities do not:
- Division 1.4, 1.5, or 1.6 explosives;
- Desensitized explosives in Division 4.1 or Class 3;
- Division 4.3 dangerous when wet materials; or
- Uranium hexafluoride.
[49 CFR 172.800(b)(2), (7), (9), and (14)]
The 2010 revisions to Subpart I created a third security category for hazardous materials. The following hazmats require security plans only when shipped in “large bulk quantities”:
- Division 2.1 flammable gases;
- Division 2.2 compressed gases with a subsidiary hazard of 5.1;
- Class 3, PG I or II;
- Division 4.2, PG I or II;
- Division 5.1, PG I, PG II, and certain ammonium nitrate compounds;
- Division 6.1 poison other than PIH; or
- Class 8, PG I.
[49 CFR 172.800(b)(3), (4), (6), (8), (10), (12), and (16)]
A “large bulk quantity” is a quantity greater than 3,000 kg (6,614 lbs.) for solids, 3,000 L (792 gal.) for liquids in a single packaging (including tank cars, cargo tanks, and portable tanks), in other words bigger than an intermediate bulk container (IBC).
Other hazardous materials not listed here (Class 8 PG II or III, Class 3 PG III, non-bulk packages of Division 2.1, Division 4.1, etc.) do not require security plans, even in placarded amounts.
A security plan must assess the transportation security risks, and describe the measures you will take to address those risks. Most importantly, if you have to have a plan you must review it at least annually and update it “as necessary to reflect changing circumstances.” [49 CFR 172.802(c)]
If you’d like more information on these requirements, you can check DOT’s FAQs on security plans.
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