Do You Need a Hazmat Transportation Security Plan?

If you offer or transport certain hazardous materials (hazmat), you may be required to develop and implement a Hazardous Materials Transportation Security Plan. In addition, Security Plan training is required for each hazmat employee whose employer is required to have a Security Plan. Here is some guidance from the U.S. Department of Transportation (DOT).

What Triggers the Need for a Security Plan?
Refer to 49 CFR 172.800 for the applicable hazardous materials and quantities that trigger the requirement for a Security Plan. In some cases, the requirement is triggered by “any” quantity being transported. For others, the requirement is triggered by “large bulk quantities.” A large bulk quantity is greater than 6,614 pounds (3,000 kilograms) for solids or 792 gallons (3,000 liters) for liquids and gases in a single packaging, such as a cargo tank motor vehicle, portable tank, tank car, or other bulk container.
Note: There are additional security plan requirements for rail carriers.

What Must the Security Plan Look Like?
The Security Plan must include an assessment of possible transportation security risks for hazmat shipments. The plan must also include site-specific or location-specific risks associated with facilities at which the hazardous materials are prepared for transportation, stored, or unloaded incidental to movement, and appropriate measures to address the assessed risks. Specific measures put into place by the plan may vary according to the level of threat at a particular time.

I’ve got a Security Plan – Now, What Training is Required?
In addition to the general security awareness training requirement applicable to all new and existing hazmat employees, additional in-depth security training is needed for each hazmat employee whose employer is required to have a Security Plan. Employers must conduct in-depth security training concerning the plan and its implementation for each employee who:
• Performs a regulated function related to the hazmat covered by the plan; and/or
• Is responsible for implementing the plan.

Need assistance developing or annually updating your Hazmat Transportation Security Plan? CTI will gladly provide a well-versed DOT expert with Department of Homeland Security clearance to assist you.

Published by Glenn Miller

Senior Compliance Manager Mr. Miller provides a broad range of consulting services to CTI’s clients based on over 30 years of experience in the chemical industry. Along with helping to coordinate CTI’s diverse consulting projects and assisting in CTI’s marketing efforts, he specializes in HazCom programs, dangerous goods handling and labeling (GHS, HMIS and NFPA), transportation compliance (DOT/IATA and IMDG), site audits, global regulatory compliance (REACH, TSCA), Process Safety Management, and training. You may direct questions to our Senior Compliance Manager, Glenn Miller, at 216.341.1800, ext. 14

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