Written Security Plan
(49 CFR 172.800) requires shippers and carriers to develop and implement a written security plan for those who ship/transport certain hazardous material that also meets requirements of federal hazmat registration requirements (49 CFR 107.601) or select substances under 42 CFR, Part 173. DOT states that you are REQUIRED BY LAW to have a written security plan in effect by 9/25/2003.
The PHMSA (Pipeline and Hazardous Materials Safety Administration) has modified some of the requirements for written security plans outlined in 49CFR 172.800, effective October 1, 2010.
If you do not have your written security plan prepared, you are not currently compliant and face potential fines of $3,000 – $7,500 (see 49 CFR 172.800 for complete information).
According to 49 CFR 172.800, the DOT requires shippers and carriers of any of the following hazardous material to develop and adhere to a written, comprehensive hazardous material security plan:
- Any quantity of a Division 1.1, 1.2, or 1.3 material
- A quantity of a Division 1.4, 1.5, or 1.6 material requiring placarding in accordance with subpart F of this part
- A large bulk quantity of Division 2.1 material
- A large bulk quantity of Division 2.2 material with a subsidiary hazard of 5.1
- Any quantity of a material poisonous by inhalation, as defined in § 171.8 of this subchapter
- A large bulk quantity of a Class 3 material meeting the criteria for Packing Group I or II
- A quantity of a desensitized explosives meeting the definition of a Division 4.1 or Class 3 material requiring placarding in accordance with subpart F of this part
- A large bulk quantity of a Division 4.2 material meeting the criteria for Packing Group I or II
- Any quantity of a Division 4.3 material requiring placarding in accordance with subpart F of this part
- A large bulk quantity of a Division 5.1 material in Packing Groups I and II; perchlorates; or ammonium nitrate, ammonium nitrate fertilizers, or ammonium nitrate emulsions, suspensions, or gels
- Any quantity of organic peroxide – Type B, liquid or solid, temperature controlled
- A large bulk quantity of Division 6.1 material (for a material poisonous by inhalation see paragraph  above)
- A select agent or toxin regulated by the Centers for Disease Control and Prevention under 42 CFR, part 73 or the United States Department of Agriculture under 9 CFR, part 121
- A quantity of uranium hexafluoride requiring placarding under § 172.505(b)
- International Atomic Energy Agency (IAEA) Code of Conduct Category 1 and 2 materials including Highway Route Controlled quantities as defined in 49 CFR 173.403 or known as radionuclides in forms listed as RAM-QC by the Nuclear Regulatory Commission
- A large bulk quantity of Class 8 material meeting the criteria for Packing Group I
* Large bulk quantity refers to a quantity greater than 3,000 kg (6,614 pounds) for solids or 3,000 liters (792 gallons) for liquids and gases in a single packaging.
If you are required to have a DOT Security Plan, it must include the following:
- An assessment of transportation security risks for shipments of hazardous material, including site-specific or location-specific risks associated with facilities at which the hazardous material are prepared for transportation, stored, or unloaded incidental to movement, along with appropriate measures to address those risks
- Measures to confirm the information provided by job applicants who will have access to hazardous material covered by the security plan
- Measures to prevent unauthorized access to hazardous material covered by the security plan, both on-site and during transport
The security plan, including the transportation security risk assessment, must be in writing and must be maintained for as long as remains in effect. The security plan must be reviewed annually and revised and/or updated as necessary to reflect changing circumstances. The most recent version of the plan, or portions thereof, must be available to employees who are responsible for its implementation. 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.
Hazardous material employees at facilities where a security plan is required must receive in-depth training on the parts of the security plan for which they are responsible. This training is required during their initial DOT training and at least every three years thereafter; or, if the security plan for which training is required is revised during the three-year recurrent training cycle, within 90 days of implementation of the revised plan. Regardless of whether a security plan is required, all hazardous material employers are required to provide security awareness training to hazardous material employees.
Let TMGI apply our expertise and assist you with your plan. Contact TMGI for a price quote.