HM-232 Revised 5-30-2008. HM-232 RSPA, the Research and Special Programs Administration, has...

HM-232 Revised 5-30-2008

HM-232

RSPA, the Research and Special Programs Administration, has

established new requirements under a final rule, HM-232, to enhance the

security of hazardous materials transported in commerce.

HM-232

All shippers and carriers of hazardous materials must make sure hazmat employees receive training that includes a security component.

Security awareness training (Part 172, Subpart H)

Hazmat employees must receive training to make them aware of security risks associated with hazmat transportation, as well as ways to ensure hazardous materials are safe during the transportation process.

The security awareness training must also cover how to recognize and respond to possible security threats.

HM-232 Training Deadlines

In-depth security training must be completed by December 22, 2003 for current employees. Training may be repeated as needed and as changes are made to the security plan.

New employees must be trained within 90 days of employment.

Security Overview

The terrorist attacks of 9/11 changed the way hazardous material (HM) is handled and transported. It resulted in: Heightened sense of awareness Need for increased security Communication of potential security risks

to all HM employees Required security awareness

training

Awareness of security risks

Need for increased security Examples of terrorist acts Important to:

Have a heightened sense of awareness

Identify potential targets and security threats

Recognize security risks that may be present

Potential security threats Potential targets and threats could

include: Gasoline or other flammable

materials/gases Poisons or materials poisonous by

inhalation Materials, that when mixed,

become potential deadly weapons Explosives

Potential security threats

Potential geographical targets may include: Historical monuments Public, state, federal

buildings/sites Water towers and

reservoirs

Potential security threats Potential geographical

targets may include (continued): Gas stations, refineries, and

industrial locations Churches, school, and

hospitals Train stations, bus

terminals, and airports


Company-specific targets and threats may include: Access points, terminal gates, and

entrances Perimeters and fenced-in areas Doorways and windows


Company-specific targets and threats may include (continued):Communication areasLimited access and restricted areasPhysical facilities and equipmentVehicles and inventory that could

be used as weapons

Security risks on the road

Terrorist activities could include:Cargo theftCargo contaminationVehicle hijackingKidnappingBodily harmDeath

Security risks on the road Additional geographical

targets/locations: Tunnels and bridges Railroad tracks and switching

areas Lakes, rivers, and dams High density population areas Virtually anywhere HM could be

ignited or detonated

Security risks on the road Be on the lookout for suspicious

activity/behavior associated with: The planned route Rest stops and truck stops Maintaining visual contact with the load Traffic lights and unplanned stops Vehicles stopped along the road People posing as authorities Unlit areas


Typical driver checklist could include: Verifying paperwork Checking on emergency response

information Accepting only HM properly packaged,

labeled, and marked for transport Supervising loading and locking of trailer Planning the quickest and safest route

with minimum stops


Typical driver checklist could include (continued): Staying alert, aware, and

observant from start to finish Securing stopped vehicle;

never leaving it unattended Keeping in touch with dispatcher/home

base Contacting authorities if threat is

observed/encountered


Carriers could consider: Establishing shipment tracking procedures Having check points and check-in times en

route Providing a 24-hour number drivers can call Keeping actual road time to

a minimum Installing locks and alarms

Suspicious activity

Points to remember: It’s okay to be suspicious Don’t ignore suspicious activity

or behavior It’s more important to report it than

to have a potential threat or target become a reality

Suspicious activity should raise a red flag to well-trained employees

Suspicious activity

Closely watch and possibly report: Unauthorized persons trying to access

equipment or off-limit areas Disgruntled employees Anyone appearing to be extremely

nervous, agitated or hiding something

Suspicious activity Closely watch and possibly report

(continued): Anyone asking sensitive questions or

requesting information when unauthorized to do so

Anyone without proper I.D. Anyone possessing a weapon Unfamiliar vehicles parked where they

don’t belong

Enhancing your transportation security Requires cooperation of everyone

involved Goes hand-in-hand with reducing

security risks Enhances transportation

security by focusing on: Personnel security Facility security En route security

Responding to alerts When DHS raises or lowers

the threat level: Employees, temporary

employees, and contractors will be expected to follow protocol introduced during formal training

Each department and employee will be instructed on additional roles and protocol for each threat level

Responding to alerts

When DHS raises or lowers the threat level: Each department or area will have a point

of contact Employees will be expected to use the

designated method of communication (e.g., cell phone, email, intranet, etc.) during the threat level

Responding to alerts The U.S. Coast Guard has

developed a tiered maritime security advisory system (MARSEC Levels), which parallels DHS codes: This system applies to port facilities Carriers, vendors, and visitors

entering port facilities will be subject to more stringent security protocols during heightened alerts for a specific port

Responding to alerts

When a MARSEC level raises or lowers at a specific port facility: Employees, temporary employees, and

contractors (such as truckers) will be expected to follow protocols set up by the port facility

http://www.uscg.mil/safetylevels/whatismarsec.html

Responding to alerts When a MARSEC level raises or lowers

at a specific port facility: Employees will be expected to use the

designated method of communication (e.g., cell phone, email, intranet, etc.) during the threat level

Employees will be expected to follow customer security measures while on their site during alerts

Security Recommendations for Drivers Before the driver leaves

Must have been hazardous materials trained, tested, and certified by employer.

Must have proper identification.

Must have proper licenses, endorsements, or permits for hazardous materials.

Must have proper shipping documents, such as hazardous materials shipping papers and emergency response information.

Know the route.

Know procedures for emergency situations.

Know who to contact in an emergency.

Security awareness training (Part 172, Subpart H)

In addition, shippers and carriers of certain highly hazardous materials must develop and implement security plans, as well as provide in-depth security training to employees.

Security plans and in-depth security training (Part 172, Subpart H & I)

The security plan must include an assessment of possible transportation security risks and appropriate measures to address the risks.

The security plan must be:

in writing and retained for as long as it remains in effect;

revised and updated as needed to reflect changing circumstances; and

made available to all employees responsible for implementing it.

At a minimum, a security plan must include the following:

Personnel security; Unauthorized access; and En route security.

Hazmat shippers and carriers required to complete a security plan must do so

by September 25, 2003.

The Security Plan Must Be:

in writing and retained for as long as it remains in effect;

revised and updated as needed to reflect changing circumstances; and

made available to all employees responsible for implementing it.

OTL-UPT Security ObjectivesPurpose To set forth policies and procedures for

protecting company resources and consigned customer cargo from acts of terrorism, hijacking, theft, and/ or intentional destruction. Company resources include, but are not limited to its personnel, equipment, facilities, and electronic media.

OTL-UPT Employee ResponsibilitiesResponsibility The Company’s Vice President

of Risk Management is responsible for the overall coordination of the Company’s Security Plan. Each department head and CSC/facility manager is accountable for the proper and timely administration of this directive within his/her assigned area(s) of responsibility. A dispatched driver is responsible for strict adherence to the precautionary security guidelines set forth in this directive. These guidelines are designed to help safeguard a driver’s personal safety, as well as to protect other company resources and consigned customer cargo.

OTL-UPT The Organizational Security StructureThe Company is totally committed to

safeguarding the personal security of its employees and lease operators, and to protect all other company resources and consigned customer cargo from acts of terrorism, hijacking, theft, and/or intentional destruction.

OTL-UPT Security PlanPersonnel Security

The Company’s Manager of Driver Resources shall ensure that comprehensive and thorough criminal background checks and previous employment verifications are completed on all applicants seeking employment or lease operator contracts with the Company. Driver applications shall be processed and evaluated in accordance with the provisions of Company Policies HR-019-000-000. The Manager of Driver Resources will ensure personnel files are properly maintained in a secure and confidential manner.

OTL-UPT Security PlanSecurity Awareness Training

Security Awareness Training - At least annually, each CSC/facility manager shall ensure that all assigned HAZMAT Employees view the safety video titled, “Truck Driver and Cargo Security”, or its corporate approved equivalent.


In addition, each HAZMAT employee shall annually read this directive in order to meet the federally mandated HAZMAT training requirements. A HAZMAT Employee is defined as any employee who performs any task covered by the Hazardous Materials Regulations.


The initial viewing of the training video shall be a mandatory component of company Safety and Security Orientation. In addition, each department head and terminal/facility manager will ensure that all assigned employees and lease operators have read this directive.


Certification of Security Awareness Training, documenting completion of this task shall be executed and forwarded to the Company’s Director of Education. A copy will be maintained on file by the department or CSC/facility for a minimum of one year after completion of this security awareness training.

OTL-UPT Security PlanEn Route Security

Secure Routing of Hazardous Material Shipments

1. No company employee shall accept new hazardous materials business from an unknown broker or potential customer without thoroughly validating the authenticity of the tendered business.


2. Driver and cargo security considerations shall be factored into the determination of each specified transportation route. Such considerations shall include, but not be limited to the avoidance, when possible, of bridges, tunnels, and densely populated areas.


3. Not withstanding mandated hours of service regulations, concerted efforts shall be made by CSC and Fleet Control Center (FCC) operational personnel to minimize in-transit driver downtime. The objective of this security measure is to help ensure that a driver, and his/her assigned equipment/cargo have minimal physical exposure to being targeted for acts of terrorism, hijacking, theft, and/or intentional destruction.


4. The Company Fleet Control Center (FCC) and or CSC Manager shall monitor the overnight parking or staging of all dispatched long-haul tractors.


5. During a long-haul trip, the assigned driver(s) shall be responsible for maintaining proper communications, with the Fleet Control Center (FCC) and or CSC. Such communications shall be in accordance with instructions issued to the driver(s) by the Fleet Control Center (FCC) and or CSC as a minimum; such routine contact by a driver shall be made every 12 hours. However, a driver shall immediately report to the Fleet Control Center (FCC) and or CSC each potential or actual security threat, safety incident, equipment maintenance problem, or operational issue that is encountered by the driver.


The Fleet Control Center (FCC) shall keep the driver’s domiciled CSC informed regarding the status of a long-haul trip, to include its transportation routing and the estimated return date and time of the assigned driver and equipment.

Drivers and Cargo Security

1. A driver shall conduct a thorough pre-trip vehicle inspection before each trip. Furthermore, a walk around vehicle inspection and security check must be completed by the driver after each loading and unloading of cargo, as well as after each time he/she takes a rest break. Any and all noted problems or concerns shall be addressed prior to the unit continuing in operation.


2. While on a dispatched load, a driver shall not discuss information related to his/her consigned cargo, planned transportation route, or product pickup and delivery schedule with any person(s) other than an authorized company employee.


3. A driver shall shut down and secure his/her assigned tractor when it is not in operation. Its doors must be locked, windows closed, and the unit’s ignition key removed.


4. A tractor and/or trailer shall not be left unattended by a driver without proper security safeguards being taken. A unit will only be parked or staged in a company-authorized location that has a high level of lighting, visibility, and security. No mobile equipment operated by the Company shall be parked on or within 5 feet of the traveled portion of a public street or highway, except for brief periods when the necessities of operation require the vehicle to be parked and make it impractical to park the vehicle in any other Place.


Furthermore, said equipment shall not be parked or staged on private property (excluding premises of a fueling or eating facility) without the knowledge and consent of the Company, and the person, who is in charge of the property, and aware of the nature of the hazardous material(s) /the trailer contents.


5. Each driver shall remain aware, alert, and observant of his/her surroundings. Any suspicious act(s) that is observed should be immediately reported by the driver to his/her CSC or the Fleet Control Center (FCC). Immediate reporting to law enforcement authorities can be accomplished by telephoning (911).

Drivers and Cargo Security 6. A driver, who believes that an act of

terrorism, hijacking, theft, and/or the intentional destruction of his/her assigned equipment is or may be in progress should attempt to keep the tractor/trailer moving in a safe and prudent manner. Such movement should continue until the attempted act has ceased and/or law enforcement authorities have been notified. However, the driver retains the right to exercise good judgment, as to whether to stop or keep the unit moving based on the degree of perceived threat to his/her personal safety.

Facility and Yard Security

Each CSC/facility manager shall ensure that the following security measures are established and maintained for his/her assigned facility and equipment.


1. No unauthorized or unescorted visitor(s) shall be allowed to venture for any reason or at anytime beyond the terminal or facility’s reception area.

2. All tractor ignition keys that are not in-use will be secured in a locked key safe. Such a safe will be locked at all times, except when a key(s) is needed or is being returned to the safe.


3. Terminal facility yard checks will be conducted by designated personnel at a frequency rate of not less than once per day. As designated in writing by the Company’s Vice President of Risk Management, in consultation with the Chief Operating Officer, a CSC with a high-risk security exposure may be required to conduct more frequent yard checks, to include after hours and on weekends, holidays.


Each yard check will be documented to depict the following information:a. The date and time of the yard check;b. Loaded trailer identification numbers;c. Empty trailer identification numbers;d. All parked/idle tractor identification

numbers.

Facility and Yard SecurityAll assigned mobile equipment shall be

accounted for by the CSC/facility. Any tractor, trailer or other vehicle appearing on the yard which cannot be identified shall be physically and cautiously inspected and investigated. Any tractor and or trailer shown as being at the terminal/facility, but not accounted for during the yard check shall be immediately addressed and followed-up on in order to determine its current location and status via the use of the applicable loading planning records. Any unauthorized person(s) or vehicle(s) discovered during a yard check shall be reported to local law enforcement or to the appropriate company official(s).


4. Loaded Haz-Mat trailers shall not be parked or left unattended at a terminal/facility or any other location without the prior approval of the Company’s Vice President of Operations, the applicable Area Manager, or a Fleet Control Center (FCC) supervisor. All loaded trailers parked or staged at a CSC/facility shall be positioned in direct view of the CSC/facility’s operations center, or visually monitored via the use of video camera(s).


Dropped loaded trailers will be parked or staged in compliance with company policy.

Electronic Media Security

The security of electronic media and equipment, as well as its use within the Company shall be in accordance with the provisions of Company Policy Manual.

Actions to take in the event of a Security Breach

Any suspicious actives, any report of a security problem or any questions

concerning the security of equipment, building, Hazardous Material or

personnel should be reported to the VP of Risk Management at 800-777-8265.

HM-232 Revised 5-30-2008. HM-232 RSPA, the Research and Special Programs Administration, has...

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Transcript of HM-232 Revised 5-30-2008. HM-232 RSPA, the Research and Special Programs Administration, has...