On October 14, 2004 a Company in Athens GA. had to pay to the DOT $4,800.00 for not having a written security plan. They had done every thing correct but because they had placarded their shipment they need a written security plan. These requirements went in to effect in December 2003 for all companies who ship hazardous material which requires placarding. Placarding is required if you are shipping containers of 55 gal or less, and the total shipment's gross weight is over 1,000 pounds, or a single containers over 119 gal for a liquid. Additionally when you are placarding you must register and pay a fee to the DOT.
If placard YOU NEED A PLAN! Or you could be next.
49 CFR ¤ 172.802 Components of a security plan
(a) The security plan must include an assessment of possible transportation security risks for shipments of the hazardous materials listed in ¤172.800 and appropriate measures to address the assessed risks. Specific measures put into place by the plan may vary commensurate with the level of threat at a particular time. 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. Such confirmation system must be consistent with applicable Federal and State laws and requirements concerning employment practices and individual privacy.
(2) Unauthorized access. Measures to address the assessed risk that unauthorized persons may gain access to the hazardous materials covered by the security plan or transport conveyances being prepared for transportation of the hazardous materials covered by the security plan.
(3) En route security. Measures to address the assessed security risks of shipments of hazardous materials covered by the security plan en route from origin to destination, including shipments stored incidental to movement.
(b) The security plan must be in writing and must be retained for as long as it remains in effect. Copies of the security plan, or portions thereof, must be available to the employees who are responsible for implementing it, consistent with personnel security clearance or background investigation restrictions and a demonstrated need to know. The security plan must be 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.
¤ 172.704 Training requirements.
(a) Hazmat employee training must include the following:
(5) In-depth security training. By December 22, 2003, each hazmat employee of a person required to have a security plan in accordance with subpart I of this part must be trained concerning the security plan and its implementation. Security training must include company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure.
If you have questions or need help the following links may be of interest...
www.hazmatlaw.com – Hazmatlaw is a website designed to facilitate a greater understanding of the laws and regulations governing the shipment of hazardous materials.
www.hazmat101.com – This site offers a monthly email newsletter featuring information and tools about hazardous materials transportation, safety, and the DOT regulations.