3.4.9 Student Book © 2004 Propane Education & Research CouncilPage 1 3.4.9 Identifying Bulk Plant Security Procedures In the wake of the September 11 th,

3.4.9 Student Book © 2004 Propane Education & Research Council Page 1

3.4.9Identifying Bulk Plant Security Procedures

In the wake of the September 11th, 2001 attacks and continuing terrorist threats, shippers, carriers, and marketers who offer, transport, or store hazardous materials have a greater responsibility for safeguarding personnel, facilities, cargo, and vehicles during the transport of hazardous materials.

In this module you will learn to identify:

(1) Regulatory requirements relating to hazmat security awareness training

(2) Regulatory requirements for developing a security plan for hazardous materials

(3) General considerations for security of the bulk plant


Requirements For Hazmat Security Awareness Training

The transportation of hazardous material is regulated under Title 49 of the Code of Federal Regulations.

49 CFR 172.704, Training Requirements, now includes two new requirements relating to Security Training.

Security Awareness Training— No later than the date of the first scheduled recurrent training after March 25, 2003, and in no case later than March 24, 2006, each hazmat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security.

New hazmat employees must receive the security awareness training within 90 days after employment.


Requirements For Hazmat Security Awareness Training

In-Depth Security Training — Each hazmat employee must be trained concerning [their company’s] security plan and its implementation. Security training must include

Propane marketers and transporters are required to have written hazardous materials security plans.

• company security objectives,

• specific security procedures,

• employee responsibilities,

• actions to take in the event of a security breach, and

• the organizational security structure.


Requirements for Hazardous Materials Security Plans

Components of a Security Plan — At a minimum, a security plan must include the following elements:

By September 25, 2003, each person [company] who offers for transportation in commerce or transports in commerce…. hazardous materials must develop and adhere to a security plan for hazardous materials.

• Personnel Security

• Unauthorized Access

• En Route Security



The security plan must be

• in writing

• retained for as long as it remains in effect

• available to the employees who are responsible for implementing it

• revised and updated as necessary to reflect changing circumstances


When the security plan is updated or revised, all copies of the plan must be maintained as of the date of the most recent revision.




To avoid unnecessary duplication of security requirements, security plans that conform to regulations, standards, protocols, or guidelines issued by [Federal agencies other than DOT}, international organizations, or industry organizations may be used to satisfy the requirements [of the DOT regulation] provided such security plans address the requirements specified in [the DOT regulation].


General Considerations for Security of the Bulk Plant

Figure 1. Example of Bulk Plant Layout



All security measures taken in regard to a railcar site, or bulk plant in general, are designed to protect against personal injury, damage to or loss of equipment, and the misuse of hazardous materials by terrorists.

Bulk Plant Security

The following actions may provide additional security to bulk plant facilities.

• Work with local law enforcement officers of facilitates frequent drive-by observations during nighttime hours.

• Restrict the availability of information related to your facility and the materials you handle.

• Improve fencing around the facility. Check the adequacy of the locks and other protective equipment.



Bulk Plant Security


• Assure lighting is adequate.

• Consider installing alarm systems and/or surveillance cameras.

• Restrict access to a single gate or entry, where possible.

• Place limits on visitor access.

• Secure valves, man ways, and other fixtures on transportation equipment when not in use.

• Secure all rail, truck or large container when stored at the marketer’s location.



Bulk Plant Security


• Use tamper-resistant or tamper-evident seals and locks on cargo compartment openings as applicable (such as rail tank car manways).

• Periodically inventory the quantity of hazardous materials on the site.

• Keep records of security incidents.

• Avoid preloading hazardous material shipments to the extent possible.

3.4.9 Student Book © 2004 Propane Education & Research Council Pages 5 & 6


Personnel Security— The owner and/or operator should review the facility’s Emergency Response Plan with all their employees. They should also instruct their employees to be aware of any people or things that seem to be suspicious and not consistent with the operation of a bulk plant.


• Require all employees to report unsafe conditions or suspicious incidents or events.

• Post the Nation’s Threat Level in all public and appropriate areas.

• Convene a brief security meeting when the threat level 1 increases and review security plans and tips with employees.

• Make sure all employees handling as transporting hazardous materials have adequate communication device in case of emergency. Test those systems frequently.



Personnel Security


• Assure that all employees have proper and up-to-date identification.

• Ask company personnel to monitor news and other information sources for events on changes in conditions and respond as appropriate.

• Conduct periodic checks of personnel and vehicles.



Homeland Security Alert Status— Operators should also be aware of the Alert status designation issued by the Office of Homeland Security.

When an Orange Alert (indicating a “High” condition) is issued, the facility operator should:

• Allow only scheduled visitors and deliveries and verify the legitimacy of visiting customers;

• Advise employees to be more vigilant and report suspicious behavior;

• Control access to areas of concern within the facility.

In addition, when the plant is unattended (such as nights or weekends), the following precautions should be observed.

• Lock plant gates.

• Close valves on all primary liquid and vapor lines.

• Lock all placarded vehicles with keys stored in a safe and secured area.



Homeland Security Alert Status

When the Office of Homeland Security issues a Red Alert (indicating a “Severe” condition), the facility operator should accomplish all items listed above, as well as:

• Advise drivers that delivery vehicles are to be returned to a pre-determined secure area at the end of their shift.

• Limit site access to one entrance.

• Increase facility surveillance.

• Inspect incoming transport vehicles prior to permitting entrance.

• Require drivers to check in with an authorized company representative at periodic intervals.



Cargo Tank Vehicle Security— Employee awareness is critical to security. RSPA’s HM-232 clearly states that the “shippers and carriers must take reasonable measures…” when developing security plans. Industry supported recommendations for cargo tank drivers include the following:

• Be aware of their surroundings and situations, which are different than what they encountered in the past. They should be advised to err on the side of conservatism and seek help from local law enforcement should they feel in danger.

• Keep all vehicle doors locked at all times.

• Always keep vehicle within sight.

• Where equipped, always carry remote shutdown activation devices even when not making a delivery.



Cargo Tank Vehicle Security— Industry supported recommendations for cargo tank drivers include the following:

• Never leave the truck unlocked while unattended.

• Do not stop to assist anyone unless they are personally known. If available, use a cell phone to call for help.

• Consider installing a security code device in bulk trucks and/or transports if these vehicles operate in major metropolitan areas.


Time to See If You Got the Key Points of This Module…

• Complete the Review on page 8.

• See if you are ready for the Certification Exam by checking off the performance criteria on page 9.

Documents

3.4.9 Student Book © 2004 Propane Education & Research CouncilPage 1 3.4.9 Identifying Bulk Plant Security Procedures In the wake of the September 11 th,