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In the last few decades suicide bombings, terrorist attacks, and domestic terrorism have increased dramatically. Many of these violent acts were conducted using hazardous materials to create mass explosions. To reduce this threat, the Hazardous Materials Regulations require shippers and carriers of certain high-value hazardous materials to have a security plan. The security plan is designed to protect high-value shipments of hazardous materials from malicious misuse, sabotage, and diversion.
Each person who offers for transportation in commerce or transports in commerce one or more of the following hazardous materials must develop and adhere to a security plan for hazardous materials. Used below, “large bulk quantity” means a quantity greater than 6,614 pounds for solids or 792 gallons for liquids and gases in a single packaging.
The security plan requirements do not apply to combustible liquids because of exceptions found in 173.150(f). In 173.150(f)(2) combustible liquids, that are not a hazardous substance, hazardous waste, or marine pollutant, in non-bulk packaging are not subject to the Hazardous Materials Regulations (this includes security plans). In addition, in 173.150(f)(3) the security plan requirements in Part 172 Subpart I are not listed as required compliance for combustible liquids in bulk packaging or combustible liquids that are also a hazardous substance, hazardous waste, or marine pollutant.
The security plan must include a risk assessment, which must include site-specific or location-specific risks associated with facilities at which the materials are prepared for transport, stored, or unloaded incidental to movement, and appropriate measures to address the assessed risks.
At a minimum, a security plan must include the following elements:
In addition, a security plan must also include:
Retention, availability, and revisions. The security plan, including the risk assessment, must be in writing and must be retained for as long as it remains in effect. Copies of the security plan must be available to the employees who are responsible for implementing it.
The security plan must be reviewed at least annually and revised and/or updated as necessary to reflect changing circumstances. When the security plan is updated or revised, all employees responsible for implementing it must be notified and all copies of the plan must be maintained as of the date of the most recent revision.
A copy of the security plan or an electronic file must be maintained at the employer’s principal place of business and must be made available upon request, at a reasonable time and location, to an authorized DOT or DHS official.
Training. Hazmat employees of employers that are required to have a security plan must receive in-depth security training on the security plan and its implementation. In-depth security training must include company security objectives, organizational security structure, specific security procedures, specific security duties and employee responsibilities, and actions to be taken by each employee in the event of a security breach.