Are You Subject to the Department of Transportation Security Planning Requirements?

Applicability
Per Federal regulations, persons who offer for transportation or transport the following hazardous materials must develop and implement security plans.  Note that a vehicle with 1001 pounds or more of hazardous materials in certain hazardous classes (e.g., corrosive, flammable, poison) must be placarded.  A 55 gallon drum weights approximately 450 pounds (assuming the density of water).  Therefore, a hazardous waste shipment can easily exceed the threshold. 

Security Plan
The Security Plan generally should include:

• information on your security assessment;
• how you address any vulnerabilities identified in the assessment;
• what security measures you have adopted;
• how, when, and by whom they will be implemented;
• your organizational structure; and
• the responsibilities of the various employee positions.

In essence, your security plan is the detailed map of how you address the security assessment.

Security Awareness Training
Security awareness training is the most basic form of training and must be administered to all hazmat employees no later than the date of the first scheduled recurrent training after March 25, 2003, or by March 24, 2006. Any hazmat employee hired after March 25, 2003 must receive their security awareness training within 90 days. The awareness training must address the security risks involved with hazmat transportation, methods designed to enhance transportation security, and how to recognize and respond to possible security threats.

In-Depth Security Training
This applies to each hazmat employee that is responsible for implementing or being aware of any part of the security plan by December 22, 2003.  New employees hired after this date must be trained within 90 days. The training should only cover the part of the plan for which the employee is responsible.

The training material and content must include instruction or information on company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure.

Recurrent Training and Recordkeeping
Currently, the hazardous materials regulations require that all hazmat employees be given recurrent training every three years on the safe handling, packaging, and transport of hazmat covered by the regulations. This training must now include security training. Additionally, the records related to employees' security training must be kept for the previous three years and for 90 days after termination of employment, as is required for other training.