Transportation and Facility Security

Pursuant to 49 CFR Part 172.704

Why Now?

General security Security of hazardous materials Workplace violence After 9-11

Regulatory Requirements

49 CFR Part 179 Administrative

responsibilities Suspicious activity Hazmat personnel

screening Information security Security inspections Facility access control

En route security Training and

information Conduct a security

risk assessment

Administrative Responsibilities

VP/GM and Branch Managers are responsible for:

– Establishing and communicating the overall security goals of the organization

Administrative Responsibilities (Continued)

Managers and Supervisors are responsible for:– Being fully knowledgeable of the security

issues and concerns of their department, area(s), and employees

– Providing detailed information on system operations including:

• Daily work processes, activities, and identifying potential security vulnerabilities

Administrative Responsibilities (Continued)

Employee responsibilities:– Employees are responsible for adhering and

conforming to all security-related work activities, processes, and procedures.

– Employees are also encouraged to provide feedback and suggestions for improving the security plan.

Suspicious Activity Employees have the responsibility to themselves and to the

company to observe and report suspicious activity Suspicious activity includes (but is not limited to):

– Unidentified person(s) attempting to gain access to property, equipment, or facilities

– Unidentified person(s) in any area of the company, office, yard, or parking lot

– Any unescorted visitor anywhere in the building or wandering around facility property

– Any person (employee or otherwise) who appears to be hiding something, is acting nervous, anxious, or secretive

– Any employee or visitor making unusual or repeated requests for sensitive or important company documents or information

Suspicious Activity(Continued)

Suspicious activity includes (but is not limited to):– Any person asking an employee to make an

unauthorized pickup/delivery – Any person loitering outside a company facility

or premises

– Any person claiming to be a representative of a utility company but cannot produce appropriate identification

– Any person carrying a weapon, e.g., a gun, knife, etc.

Reporting Suspicious Activity

Employees have the responsibility to themselves and to AC&S – HTP to report any suspicious activity

Use common sense when determining suspicious activity

Report suspicious activity immediately to your supervisor and/or next level manager

Hazmat Personnel Screening

The facility administrator will will verify information provided by hazmat employees including:– Previous employment history– Proof of citizenship– Driving record– Driver qualifications (as defined in company policy)– Alcohol screening

Information Security

All information (hard copy or electronic) shall be restricted to employees on a “need-to-know basis”– Work/load assignment sheets will be sequentially

numbered and secured– Access to load information must be limited to operation

personnel only– For security purposes:

• The packing slip or bill of lading number must be clearly communicated

• Trailer numbers on all work assignments are verified• Shippers packing slip or bill of lading number is verified

– In the event a trailer must be staged overnight, all load related documentation will be secured in an office and not in the vehicle

Security Inspections

The security plan requires specific security inspections of the following:– Fences– Gates– Exterior doors– Perimeter

Inspections forms have been revised to include the above checks

Facility Access Control

Main entrance, e.g. point of entry– Warehouse office

– Front office

Non-AC&S/HTP personnel on company property:– Visitor requirements

– Contractor requirements

– Outside driver requirements

Employee and visitor parking Loitering on company property

En-Route Security

Qualifying motor carriers– Approved hazmat carriers list– Verify the identity of the driver and motor carrier– Ask the driver for the name of the consignee and

destination Point of origin security

– Drivers shall check in with appropriate personnel and provide identification (if requested) upon arrival at pick-up/drop-off location

– Drivers will follow all safety and/or security instructions at the customer facility as requested

En-Route Security(continued)

Shipper Load and Count– In the event a driver is scheduled to pick-up a

trailer pre-loaded with hazmat, the driver shall verify the following:

• The loads shipping papers

• Seal numbers (if applicable)

• Trailer number

• If a discrepancy is found between the cargo and bill of lading or shipping manifest, the driver shall contact their supervisor for instructions immediately

En-Route Security(continued)

En-Route security procedures– Drivers will coordinate with their

supervisor/dispatcher to prepare and execute a routing sheet for all hazmat movements including;

• Routes or schedules to avoid highly populated areas, bridges, and tunnels when possible

• Fueling/break locations and times

• Times of daily/routine check calls

• Estimated times of arrival to stop offs and return

En-Route Security(continued)

En-route driver security procedures:– Drivers are prohibited from discussing information related

to their load, route, or delivery schedule with any person other than authorized company officials

– Report any suspicious activity to your supervisor immediately

– Drivers must make all reasonable precautions to prevent damage or theft of hazmat while in transit

– Inspect your vehicle after every stop for evidence of tampering

– Park only in safe and authorized areas– Drivers will lock their doors and keep windows closed

while in urban areas

Required Documents and Equipment

Required Documents:– Proof of insurance– Copy of Federal DOT Hazmat registration– Copy of CHP (or applicable state) Hazmat

license– Copy of applicable DOT exemptions– Vehicle registration– Accident reporting kit

• All of the above should be kept together and easily accessible

Required Documents and Equipment

Required Equipment: – Drum overpak– Case overpak– Drain cover– Spill socks– Spill pads

• All of above equipment can be placed inside the overpak drum

Conclusion

A hazmat transportation security plan is required by DOT

Security is common sense Everyone is responsible for ensuring

hazmat is kept safe and secure Additional company polices and procedures

already in place