Hazardous chemicals, by their very name, tell us that they require special care when handling, moving, and transporting. To ensure safe transport of these chemicals, the US DOT established the Hazardous Materials Regulations (HMR) at 49 CFR.
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Traditionally, these rules were intended to reduce the likelihood of accidental
release while in transportation. Unfortunately, history has shown that there are individuals and groups with nefarious motives. Hazardous materials can be targeted by these persons for intentional
This is why the DOT added the hazmat security requirements on March 25, 2003 [68 FR 14510
When a hazmat security plan is required, the shipper and carrier must evaluate the security risks associated with the high-hazard materials and implement procedures to reduce the likelihood of theft or release of hazardous chemicals during transport.
Does your facility need to comply with these requirements?
Today we will review the applicability of the hazmat security plan rules and the critical elements of a plan.
Do I Need a DOT Hazmat Security Plan?
Shippers and carriers who deal with certain high-consequence hazardous materials must develop and implement a hazmat security plan [49 CFR 172, Subpart I].
To determine whether your facility needs a written hazmat security plan, you must review three possible “triggers” for the HMR security plan requirements.
If you ship any of the following, you need a DOT hazmat security plan:
- Shipments of certain high-hazard materials in any quantity:
- Division 1.1, 1.2, or 1.3 explosives
- Poison by inhalation (PIH) materials
- Division 5.2, Type B temperature-controlled (liquid or solid)
- Select agents or toxins regulated by the Centers for Disease Control and Prevention (CDC)
- Highway route-controlled and other high-consequence Class 7 materials
- Large bulk quantities of certain hazardous materials. That is a single package greater than 3,000 kg or 3,000 L (e.g., cargo tanks for bulk chemical shipments):
- Division 2.1
- Division 2.2, with Division 5.1 subsidiary hazard
- Class 3, PG I or II
- Division 4.2, PG I or II
- Division 5.1, PG I or II (also certain ammonium nitrate compounds)
- Division 6.1 other than PIH
- Class 8, PG I
- Placard-able shipments of certain hazardous materials:
- Division 1.4, 1.5, or 1.6 explosive
- Desensitized explosives in Division 4.1 or Class 3
- Division 4.3
- Uranium hexafluoride
[49 CFR 172.800(b)]
Should My Security Plan Address All My Hazmat Shipments?
Your hazmat security plan does not have to address all
hazmat shipments. But, it must cover any shipments that meet any of the three triggers above.
So, if a shipper offers Class 3, PG II
materials in non-bulk packages sometimes and in bulk cargo tank shipments at other times, the hazmat security plan only needs to address the bulk
What’s In a DOT Hazmat Security Plan?
Shippers and carriers must address the security risks for each type of high-hazard shipment with respect to three areas:
- Personnel security
- Facility security
- En-route security
Hazmat security is about risk reduction. In all three cases, the shipper or carrier should address what actions will be taken to reduce any observed or anticipated risks. For example, a shipper may recognize that there is a higher risk for persons handling covered high-hazard materials to steal or target for release. If so, the facility may include a provision for conducting background checks of those personnel in the hazmat security plan.
A hazmat security plan will need to include specific security procedures for personnel responsible for implementing aspects of the plan. In addition, the plan will need to address a hazmat security training plan for those employees. The DOT security training under 49 CFR 172, Subpart H includes two different elements:
- Security awareness – this is training that all hazmat employees must receive—whether or not the company must have a hazmat security plan.
- Security plan training – this is the job-specific training that must be provided to hazmat employees who have specific procedures or duties outlined in their employer’s hazmat security plan. This is training that is provided on a “need-to-know” basis. Do not train all your hazmat employees in the details of your hazmat security plan. Doing so would greatly diminish its effectiveness.
You can find several other required elements of a hazmat security plan at 49 CFR 172.802. Careful and thoughtful evaluation, planning, and implementation will go a long way in securing high-risk hazmat shipments and protecting public property and life as well as the company’s good standing in the community.
Meet DOT and IATA training mandates
Dangerous Goods Shipper Training
(49 CFR, IATA DGR, and IMDG Code)
in cities nationwide in 2018. Be confident your shipments are in full compliance with the latest 49 CFR and DGR requirements for ground or air transport, earn CM Points and CEUs, and leave with trusted resources to simplify compliance and support your decisions.
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Renew your DOT hazmat training here with the recurrent online course
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on May 3.
Scott Dunsmore is a Certified Environmental Trainer (CET) who serves as Vice President of Training and Business Development at Lion Technology. Scott presents live webinars for Lion Members and EH&S professionals throughout the year.