Hazardous Materials Security Plans

What components must be included in a Security Plan?

A security plan must include an assessment of possible transportation security risks for shipments of the hazardous materials covered by the plan and appropriate measures to address the assessed risks. At a minimum, a security plan must include the following elements:

1. Personnel security - Measures to confirm information provided by job applicants hired for positions that involve access to and handling of the hazardous materials covered by the security plan.
2. Unauthorized access - Measures to address the possibility that unauthorized persons may gain access to the hazardous materials covered by the security plan or to transport conveyances being prepared for transportation of the hazardous materials covered by the security plan.
3. En route security - Measures to address the security risks of shipments of hazardous materials covered by the security plan en route from origin to destination, including shipments stored incidental to movement.

Sample Fines (civil penalties)

* Failed to register with PHMSA; offered corrosive liquid, acidic, inorganic, n.o.s. (nitric acid), 8, accompanied by a shipping paper that failed to provide the basic hazardous material shipping description , included additional information within the shipping description, and provided an unauthorized emergency response telephone number; failed to provide general awareness, function-specific, safety, and security awareness training. $4,700

* Failed to register with PHMSA; offered ammonium nitrate-fuel oil mixture, 1.5D, without providing a hazardous material shipping paper; failed to provide general awareness, function-specific, safety, and security awareness training.  $4,725

* Modified DOT specification IM-101 tanks without obtaining approval for the modification from a DOT approval agency; failed to provide general awareness, function-specific, and security awareness training and create and maintain training records.  $7,380

* Failed to develop and adhere to a security plan; offered corrosive solid, n.o.s. (sodium metasilicate), in unauthorized non-UN standard 7-gallon open-head plastic pails. $5,900

There are many many more. The common elements in almost all of them are 1) no security plan and/or 2) mandated training not done. DOT Compliance Help can help in both areas for a fraction of what a fine might cost.