The latest political scandal at the time of this writing, and likely to be eclipsed by a new one by the time you read this, involves the President’s Secret Service detachment and a bevy of prostitutes in a Columbia hotel room. While listening to a panel discussion regarding this topic on National Public Radio, I heard something that triggered thoughts of the Enhanced Transportation Security Requirements of the US Department of Transportation. What caught my ear was the term used by a spokesman for the Secret Service agents as a form of damage control. He said that the alleged incident did not represent a “security breach”. He justified this by pointing out that no unauthorized personnel gained access to sensitive information. “True”, thought I, but while this may not represent a “security breach” it definitely represents a “possible security threat”. As a HazMat Employer, you must be aware of the difference between these two terms since they are topics to be covered in your HazMat Employee Training.
HazMat Employee Training includes the following 5 topics:
- General Awareness/Familiarization
- Function Specific
- Safety/Emergency Response
- Security General Awareness
- In-Depth Security Training
The first four are required for all HazMat Employees. Initial training must be provided within 90 days of new employment and full renewal training must be provided every three years. The fifth: In-Depth Security Training is required only for those facilities subject to the applicability determination of 49 CFR 172.800(b). Security General Awareness Training (required for all HazMat Employees) must include how to recognize and respond to a possible security threat. This contrasts with the In-Depth Security Training requirement to train applicable HazMat Employees on the specific actions to take in the event of a security breach. They sound alike, but are very different and your training must reflect this important difference.
Unfortunately the DOT does not provide definitions of these terms in its regulations or guidance documents. However, when a definition does not exist, the Agency directs us to use the accepted definition found in a dictionary. Following that guidance we can begin to focus on the key differences between these two terms and how it will affect your training.
Possible Security Threat – The key word here is “Threat” which is defined as, “an indication or warning of probable trouble”. In other words, nothing bad has happened…yet, but the warning signs are there, the potential for a security breach exists. It is critical that your HazMat Employees are able to recognize this warning of probable trouble when they see it and know how to respond appropriately. Signs of a possible security threat are:
- Security doors not latching properly or left open.
- Poor inventory control resulting in hazardous materials stored out-of-place.
- Inadequate or missing lighting.
- Fencing or other physical barriers compromised by damage or poor housekeeping (eg. pallets stacked near fence).
- Person (coworker, vendor, visitor, other ) acting strangely.
- And many others that may be specific to your site.
The proper response when a possible security threat is observed is going to vary based on your site-specific conditions, but when I provide HazMat Employee training I indicate the proper response is to observe and report through your facility’s proper channels of communication.
Security Breach – “Breach” is defined as, “to make a gap in and break through a wall, barrier, or defense”. This is the terrorist, criminal, or vandal act that the possible security threat may have warned us about earlier. That is, something has gone wrong, some act has been taken by a party that has had a negative impact on your facility or your operations. A security breach may be any of the following:
- Unexplained spill or leak.
- Signs of tampering around a lock or seal.
- Hazardous materials in an incorrect location.
- Damage to property or vandalism.
- And other site-specific signs.
Your response to a security breach will depend on your site and the skills and training of your HazMat Employees. In most situations, the response will be similar to that of a possible security threat (ie. “observe and report). But, given the higher level of risk, you may train your HazMat Employees to activate the alarm system, inform trained security personnel or law enforcement or take other steps documented in your Security Plan.
Remember: how to respond to a possible security threat is only one part of the full training requirement for Security General Awareness, which itself is only one of the four mandated components of HazMat Employee Training. The need to address the specific actions to take in the event of a security breach is one of the requirements of In-Depth Security Training. Review 49 CFR 172.800(b) to see if this training requirement and the Security Plan are applicable to your facility.
HazMat Employee Training is a big responsibility, and since it is required only once every three years, it is critical to get it right. Contact me for a free consultation on your HazMat Employee training needs. You may also review the information on the DOT Security website.