Search

Question of the Week: When do I need a Security Plan?

Posted on 1/17/2012 by James Griffin

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.
 

Tags: DOT, hazmat shipping, reporting and recordkeeping

Find a Post

Compliance Archives

Lion - Quotes

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!

Oscar Fisher

EHS Manager

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

No comparison. Lion has the best RCRA training ever!!

Matt Sabine

Environmental Specialist

Download Our Latest Whitepaper

In most cases, injuries that occur at work are work-related and must be recorded to maintain compliance with OSHA regulations. This report shows you the 9 types of injuries you don’t record.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.