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DOT Security Awareness Rule Requirements HM 232

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Title: DOT Security Awareness Rule Requirements HM 232


1
DOT Security Awareness Rule Requirements (HM 232)
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2
REGULATORY REQUIREMENT HM-232 - effective March
25, 2003
  • On March 25, 2003, USDOT's Research and Special
    Programs Administration (RSPA) published its
    much anticipated final rule "Hazardous Materials
    Security Requirements for Offerors and
    Transporters of Hazardous Materials" (57 FR
    14510).
  • Upon considering comments from the public on the
    proposed security and training measures, RSPA
    made significant revisions to the regulatory
    language that was contained in the proposed
    rulemaking, dated May 2, 2002.
  • The overall intent of this rulemaking is to
    enhance the security of certain highly-hazardous
    materials being transported in commerce by
    requiring offerors and transporters to develop
    and implement security plans and train their
    employees accordingly.
  • This is RSPA's first step in what is expected to
    be a series of rulemakings to enhance the
    transportation of hazardous materials.

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3
REGULATORY REQUIREMENT HM-232 - effective March
25, 2003
  • New security plan requirements have been codified
    in 49 CFR, Part
  • 172, new Subpart I.
  • Training requirements of section 172.704 have
    been revised to
  • require security awareness and in-depth security
    plan training and
  • testing for hazmat employees.
  • Security plans must be developed and implemented
    by
  • September 25, 2003.

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4
Proposed Shipment Requirements Not Included in
the Final Rule
  • Comments from industry on this proposal, although
    supportive on RSPA's initiative to enhance
    security, were largely in opposition to many of
    the security requirements in the May 2002
    proposal.
  • The primary concerns from commenters, were that
    many of the security requirements would result
  • in unacceptable economic burdens on the
    transportation industry,
  • would adversely affect the efficiency of the
    transportation of hazardous materials, and
  • most importantly, would not significantly improve
    the overall security of hazardous materials in
    transportation.

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5
REGULATORY REQUIREMENT HM-232 - effective March
25, 2003
  • As a result of industry comments, RSPA
    reconsidered their position and decided not to
    include the following proposed shipping
    requirements in the final rule
  • motor carriers registered with RSPA must maintain
    a copy of the of its current registration
    certificate on each motor vehicle used to
    transport hazardous materials,
  • hazardous material shipping papers must include
    the name and address of the consignor and
    consignee,
  • hazardous material shipping papers must include
    the RSPA Hazmat Registration Number of the
    offeror if applicable.

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6
New Security Training Requirements
  • The first major component of this new rule is the
    requirement to provide security training to
    employees involved in the transportation of
    hazardous materials. The training is separated
    into two types
  • "security awareness training" and
  • "in-depth security training"
  • The new training requirements have been
    incorporated into 49 CFR 172.704.

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7
Security Awareness Training
  • All hazmat employees must receive training that
    provides an awareness of security risks
    associated with hazardous materials
    transportation and methods designed to enhance
    transportation security.
  • It must also include a component covering how to
    recognize and respond to possible security
    threats.

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8
SECURITY TRAINING
  • New hazmat employees must receive security
    awareness training within 90 days after
    employment.
  • Existing hazmat employees must receive security
    awareness training no later than their first
    scheduled recurrent training after March 25,
    2003, and in no case, complete training later
    than March 24, 2006.
  • Essentially, hazmat employers now need to assure
    that during their next routinely scheduled DOT
    hazmat refresher training class that a module on
    security awareness training is included.

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9
SECURITY AWARENESS TRAINING
  • Training that provides an awareness of
  • the security risks associated with hazardous
    materials transportation,
  • methods designed to enhance transportation
    security, and
  • instructions on how to recognize and respond to
    possible security threats.
  • USDOT has provided a Hazmat Transportation
    Security Awareness Training Module for use in
    completing the security awareness training
    requirement.

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10
In-depth Security Training
  • An additional level of training is required for
    those hazmat employees whose employer is required
    by this rule to have a security plan.
  • The in-depth security training must include
    training concerning the company's security plan
    and its implementation.
  • Specifics to be covered in this training include
    the
  • company's security objectives,
  • specific security procedures,
  • employee responsibilities,
  • employee actions in the event of a security
    breach, and
  • the organizational security structure.

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11
In-depth Security Training
  • OSHA, EPA and other agency required security
    training may be used to satisfy the DOT
    requirements to the extent that such training
    addresses the new DOT security training
    requirements described above.
  • Hazmat employees of a person required to have a
    security plan must receive the in-depth security
    training by December 22, 2003.

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12
New Security Plan Requirements
  • The focus of this final rule is for certain
    hazmat employers to develop and implement a
    formal security plan in an effort to enhance the
    security of certain highly-hazardous materials in
    transportation.
  • Applicability Any person who offers for
    transport, or transports any of the listed
    hazardous materials in 49 CFR 172.800 must
    develop and implement a security plan.

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13
New Security Plan Requirements
  • This includes the loading, unloading and storage
    operations incidental to the movement of
    hazardous materials in commerce. The listed
    hazardous materials in 172.800, includes
  • all hazardous materials listed in 49 CFR 107.601
    for which the offering or transportation requires
    registration with RSPA, and
  • any select agent or toxins regulated by the
    Center of Disease Control (CDC) in 42 CFR Part
    73.
  • Basically, anyone offering or transporting a
    hazardous material that requires placarding will
    now be required to have a security plan.

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14
COMPLIANCE DATE
  • Those required to have a security plan must have
    the plan developed and implemented by September
    25, 2003.

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15
COMPONENTS OF THE SECURITY PLAN
  • The security plan requirements have been
    incorporated in a new section, 172.802.
  • In general, the plan must include an assessment
    of the possible transportation security risks for
    the shipments of hazardous materials listed in
    172.800 and include appropriate measures to
    address those risks.
  • The security measures described in the plan may
    vary commensurate with the level of threat in the
    nation at a particular time.

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16
COMPONENTS OF THE SECURITY PLAN
  • In an effort to assist companies in performing an
    assessment of transportation security risks,
    USDOT has developed a security template that may
    be used to identify security enhancement
    opportunities. This optional template is
    accessible at http//hazmat.dot.gov/rmsef.htm.
  • There are three basic elements that must be
    included in the plan
  • Personnel security
  • Unauthorized access
  • En route security

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17
PERSONNEL SECURITY
  • Defined as Measures to confirm information
    provided by job applicants for positions that
    involve access to or handling of the hazardous
    materials covered by the security plan.
  • Companies are required to take reasonable and
    prudent measures to address personnel security.
    This may include confirming applicant information
    such as employment history, references, and
    citizenship status.

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18
UNAUTHORIZED ACCESS
  • Measures to address the risks of unauthorized
    persons gaining access to hazardous materials
    covered by the security plan or the vehicles used
    to transport those covered materials.

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19
EN ROUTE SECURITY
  • Must include measure to address the security
    risks during the transportation of covered
    materials from origin to destination, including
    all incidental storage and handling.

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20
ADMINISTRATION OF THE SECURITY PLAN
  • The security plan must be in writing and copies
    of the plan provided only to employees who are
    responsible for implementing it.
  • The plan must be revised and updated as necessary
    to reflect changing circumstances and retained
    for as long as it remains in effect.

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