Hazmat Security Plans: Who Must Have One?
The Hazardous Materials Regulations (HMR) require some shippers and carriers to develop and implement a plan to address security risks related to hazardous materials transportation, often referred to as a Security Plan.
Who Must Have a Hazardous Materials Security Plan?
There are sixteen “triggers” that require a shipper or carrier to implement a hazmat security plan, listed in 49 CFR 172.800(b). Below, we organize these applicability criteria into three categories for the sake of clarity.
Any person (i.e., site, company, etc.) who offers or transports any of the following types and/or quantities of hazardous materials “in commerce” must have a hazardous materials security plan:
Any quantity of any of the following high-hazard materials:
Explosives in Division 1.1, 1.2, or 1.3,
Poison-by-inhalation (PIH) materials,
Organic Peroxides (Division 5.2), Type B, liquid or solid, temperature-controlled,
Select agents or toxins regulated by the Centers for Disease Control (42 CFR 73) or Department of Agriculture (9 CFR 121), or
Radioactive materials (7) in highway-route-controlled quantities, and other high-consequence Class 7 shipments.
A large bulk quantity* of any of the following hazardous materials:
Flammable gases (2.1),
Non-flammable gases (2.2) with an oxidizer (5.1) subsidiary hazard,
Flammable liquids (3) in Packing Groups I or II
Spontaneously combustible materials (4.2) in PG I or II
Oxidizers (5.1) in PG I or II; perchlorates; or certain ammonium nitrate compounds,
Poisons (6.1) other than poison-by-inhalation (PIH), or
Corrosives (8) in PG I.
When shipped in quantities that require placarding, any of these hazardous materials:
Explosives in Division 1.4, 1.5, or 1.6,
Desensitized explosives in Division 4.1 or Class 3,
Dangerous When Wet materials (4.3), or
[49 CFR 172.800(b)(1)–(16)]
*"Large bulk quantity" means greater than 3,000 kg for solids or 3,000 L for liquids/gases in a single package (e.g., a cargo tank motor vehicle, portable tank, or tank car).
DOT established hazardous materials security planning requirements in 2003, and adjusted the regulations for security plans in 2010 so that fewer shippers and carriers were required to create a plan (75 FR 10974).
Should a Security Plan Address Every Shipment?
Your hazmat security plan does not have to address all of your hazmat shipments. It must cover any shipments that fit any of the criteria above.
For example: If a shipper offers a PG II flammable liquid (Class 3) in non-bulk packagings sometimes and in bulk packagings (e.g., a cargo tank) at other times, the hazmat security plan only needs to address the bulk chemical shipments.
Security Training and Security Awareness Training
“In-depth security training,” is required for hazmat employees who have responsibilities under the employer’s hazmat security plan, when the employer is required to have one (49 CFR 172.704(a)(5)).
An employee's responsibilities under the hazmat security plan might include:
- Handling hazardous materials covered by the plan,
- Performing a regulated function related to the materials covered by the plan, or
- Being responsible for implementing the plan.
The in-depth security training for hazmat employees must include:
- Company security objectives,
- Organizational security structure,
- Specific security procedures,
- Specific security duties and responsibilities for each employee, and
- Specific actions to be taken by each employee in the event of a security breach.
For employees with responsibility under the hazmat security plan, security training must be included as part of both the initial training (required within 90 days) and recurrent training (required every 3 years).
“Security awareness,” is a required element of training for all “hazmat employees.” Security awareness training refers to instruction that informs the employee about security risks associated with hazardous materials transportation, methods to enhance security, and how to recognize and respond to threats (49 CFR 172.704(a)(4)).
Where the hazmat regulations in general aim to prevent and mitigate accidents involving hazardous materials in transportation, hazmat security plans focus on ensuring that the most consequential shipments are protected from malicious misuse, sabotage, and diversion.
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