49 CFR 172, Subpart I requires shippers and carriers of certain hazardous materials to create and maintain a Safety and Security Plan. §172, Subpart H indicates that a shipper or carrier required to have the Safety and Security Plan must also conduct In-Depth Security Training for certain HazMat Employees. The criteria for applicability of the Safety and Security Plan can be found at §172.800(b). If applicable, your Safety and Security Plan must contain certain elements, including but not limited to:
- A site security assessment.
- Personnel security.
- Unauthorized access.
- En route security
You can read more about the HazMat Security Requirements of the PHMSA here: Hazardous Materials Security. This article will provide guidance on how to complete the Site Security Assessment.
The first step in developing the HazMat Safety and Security Plan is to conduct a security assessment of your site. Start by listing the hazardous materials that you handle and identify any that have a potential security risk. Per the regulations, your assessment need only include those hazardous materials listed at 49 CFR 172.800(b) that you handle, however, you may wish to consider all hazardous materials at your facility. Once you have your list, ask yourself these questions:
- “How and where are we handling the hazardous material now?”
- “What could possibly go wrong?”
- “What could we do differently?”
Instead of thinking of your hazardous materials as purely a health and safety issue, consider the following:
- Does your HazMat have a monetary value making theft a concern?
- Does your HazMat have the potential to be used as a weapon of mass destruction?
- Could your HazMat be subject to an act of vandalism?
It may be helpful to use the Risk Management Self-Evaluation Framework Security Template on PHMSA’s website to conduct your Security Assessment; it includes the following steps:
- SCOPING – Determine the scope of operations that should be subject to security risk management. Identify the types of HazMat you handle and the modes of shipment used.
- KNOWLEDGE OF OPERATIONS – Collect detailed information about your transportation operations, such as: the quantities of HazMat transported, baseline security programs, current security procedures, and related safety programs and procedures.
- ASSESSMENT – Analyze potential security threats and identify security risk control points. Risk control points are points in the transportation process where you can make an impact by improving procedures or operations.
- STRATEGY – Rank or group security risks, prioritize opportunities for security risk reduction, and decide on preventative actions. Create a written document summarizing your decisions. This written document is your Safety and Security Plan.
- ACTION – Implement your Safety and Security Plan.
- VERIFICATION – Monitor implementation of your Safety and Security Plan.
- EVALUATION – Determine if goals are being met and compare your strategy and results with others in your field.
As noted above, the Site Security Assessment is just one element of your Safety and Security Plan. There are other required elements along with specific information (ie. name & job title of senior official responsible for developing and implementing the Plan, etc.). This first step is the most important as the remaining elements will all depend on your assessment. Be sure to carefully complete and document your Site Security Assessment to comply with the Hazardous Material Regulations.
Please don’t hesitate to contact me with any questions about the HazMat Security requirements of the PHMSA/USDOT.