Hazmat Security: A Critical Tool in the War on Terror
Renew your hazmat shipper certification and take away resources designed to simply compliance. The DOT Hazmat Ground Shipper Certification Workshop comes to Los Angeles, Las Vegas, Sacramento, Denver, Kansas City, and Minneapolis in April—and doesn’t stop there.
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 release.
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.
Shippers and carriers who deal with certain high-consequence hazardous materials must develop and implement a hazmat security plan [49 CFR 172, Subpart I].
Do I Need a DOT Hazmat Security Plan?
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)]
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.
Should My Security Plan Address All My Hazmat Shipments?
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 chemical shipments.
Shippers and carriers must address the security risks for each type of high-hazard shipment with respect to three areas:
What’s In a DOT Hazmat Security Plan?
- Personnel security
- Facility security
- En-route security
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.
Meet DOT and IATA training mandates 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.
Dangerous Goods Shipper Training
(49 CFR, IATA DGR, and IMDG Code)
Need DOT (49 CFR) hazmat training for highway shipments? Check out the Hazmat Ground Shipper workshop or online course here.
Renew your DOT hazmat training here with the recurrent online course or live, one-day refresher webinar 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.
Tags: 49, CFR, hazmat, hazmat security, HMR, I, security plan, subpart
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