NEW DOTNEW DOTSECURITY SECURITY

REGULATIONSREGULATIONSRussell S. Hanson Russell S. Hanson

Peter C. AshbrookPeter C. Ashbrook

U of Missouri-ColumbiaU of Missouri-Columbia

November 13, 2003November 13, 2003

49 CFR 172 Subparts 49 CFR 172 Subparts A - GENERALA - GENERAL B - TABLE OF HAZARDOUS MATERIALS AND B - TABLE OF HAZARDOUS MATERIALS AND

SPECIAL PROVISIONSSPECIAL PROVISIONS C - SHIPPING PAPERSC - SHIPPING PAPERS D - MARKINGD - MARKING E - LABELINGE - LABELING F - PLACARDINGF - PLACARDING G - EMERGENCY RESPONSE INFORMATIONG - EMERGENCY RESPONSE INFORMATION H - TRAININGH - TRAINING I - SECURITY PLANSI - SECURITY PLANS APPENDICESAPPENDICES

Added by HM-232Effective Date: 3/25/03

Comply by: 9/25/03

49 CFR 172.80049 CFR 172.800ApplicabilityApplicability

Applies to each “person” who offers for transport in commerce or Applies to each “person” who offers for transport in commerce or transports in commerce, one of the following:transports in commerce, one of the following:

Highway Route-Controlled Class 7Highway Route-Controlled Class 7 More than 25 kg of Division 1.1, 1.2, 1.3More than 25 kg of Division 1.1, 1.2, 1.3 More than 1 L per package PIH Zone AMore than 1 L per package PIH Zone A Bulk shipments of 3,500 gal for liquids and 468 cubic feet for Bulk shipments of 3,500 gal for liquids and 468 cubic feet for

solidssolids5.5. Non-bulk shipments of 5,000 lbs gross wt of one hazard class Non-bulk shipments of 5,000 lbs gross wt of one hazard class

requiring placardingrequiring placarding6.6. A select agent or toxin regulated by CDCA select agent or toxin regulated by CDC7.7. A quantity of hazardous material that requires placardingA quantity of hazardous material that requires placarding

MU EHS Security PlansMU EHS Security Plans

HW ShipmentsHW Shipments Separate Plan for each Disposal Service VendorSeparate Plan for each Disposal Service Vendor

Rad Waste Pick upsRad Waste Pick ups Plan currently limited to MU CampusPlan currently limited to MU Campus

Yellow-III Rad Package DeliveriesYellow-III Rad Package Deliveries Draft Plan as a contingencyDraft Plan as a contingency

Other Plans developed as neededOther Plans developed as needed e.g. select agentse.g. select agents

49 CFR 172.70449 CFR 172.704(Amended) Training Requirements(Amended) Training Requirements

What is Required?What is Required? General Awareness/Familiarization TrainingGeneral Awareness/Familiarization Training Function-specific TrainingFunction-specific Training Safety TrainingSafety Training

172.704(a)(1) – (3)172.704(a)(1) – (3)

Security Awareness TrainingSecurity Awareness Training 172.704(a)(4)172.704(a)(4)

In-Depth Security TrainingIn-Depth Security Training 172.704(a)(5)172.704(a)(5)

NEW

SECURITY TRAININGSECURITY TRAINING

Security Awareness TrainingSecurity Awareness Training Required for all hazmat employeesRequired for all hazmat employees Previously trained hazmat employees need not be Previously trained hazmat employees need not be

trained until they receive recurrent training (by trained until they receive recurrent training (by 3/24/2006)3/24/2006)

In-Depth Security TrainingIn-Depth Security Training Only required when the hazmat employer must have a Only required when the hazmat employer must have a

Security Plan (within 90 days of plan development or Security Plan (within 90 days of plan development or employee hire)employee hire)

49 CFR 172.80249 CFR 172.802Components of a Security PlanComponents of a Security Plan

Personnel SecurityPersonnel Security Unauthorized AccessUnauthorized Access En Route SecurityEn Route Security

DOT web site: hazmat.dot.gov/hmt_security.htmDOT web site: hazmat.dot.gov/hmt_security.htm

Organization of PlansOrganization of Plansas recommended by MUas recommended by MU

Statement of PurposeStatement of Purpose Scope of PlanScope of Plan Security Plan Elements (DOT required Security Plan Elements (DOT required

components)components) AvailabilityAvailability

Statement of PurposeStatement of Purpose(MU Suggestion)(MU Suggestion)

Commitment to safetyCommitment to safety Commitment to security of…Commitment to security of…

FacultyFaculty StaffStaff StudentsStudents General PublicGeneral Public

Scope of PlanScope of Plan(MU Suggestion)(MU Suggestion)

Type of shipment covered by the planType of shipment covered by the plan OriginOrigin DestinationDestination ConveyanceConveyance

The Plan is further restricted to the The Plan is further restricted to the Transportation EventTransportation Event

Transportation EventTransportation Event(MU Suggestion)(MU Suggestion)

Example Event types:Example Event types: LoadingLoading UnloadingUnloading DrivingDriving

MU responsibilitiesMU responsibilities EHSEHS Other MU Departments, if anyOther MU Departments, if any

Non-MU Driver responsibilitiesNon-MU Driver responsibilities Where applicableWhere applicable

Security Plan ElementsSecurity Plan Elements(DOT Required)(DOT Required)

Personnel SecurityPersonnel Security Background Screening (Human Resources)Background Screening (Human Resources)

Notes: Notes: All of these individuals are designated as hazmat All of these individuals are designated as hazmat

employeesemployees CDL for Driver, if applicableCDL for Driver, if applicable

Security Plan ElementsSecurity Plan Elements(DOT Required)(DOT Required)

Unauthorized AccessUnauthorized Access Start of Transportation EventStart of Transportation Event Security PersonSecurity Person How to respond to unauthorized personsHow to respond to unauthorized persons

Access concerns during Loading and Unloading Events Access concerns during Loading and Unloading Events addressed in this sectionaddressed in this section

Access concerns during Driving Events are addressed in Access concerns during Driving Events are addressed in the En Route Security sectionthe En Route Security section

Conclusion of Transportation EventConclusion of Transportation Event

Security Plan ElementsSecurity Plan Elements(DOT Required)(DOT Required)

En Route SecurityEn Route Security MU DrivingMU Driving

Prior to DeparturePrior to Departure En Route Security provided by MUEn Route Security provided by MU

EHSEHS Police (MUPD, Other)Police (MUPD, Other)

Non-MU DrivingNon-MU Driving Prior to DeparturePrior to Departure After DepartureAfter Departure En Route Security provided by Driver’s CompanyEn Route Security provided by Driver’s Company

Security Plan ElementsSecurity Plan Elements(Required by DOT, but not necessarily (Required by DOT, but not necessarily

in Security Plan, itself)in Security Plan, itself)

TrainingTraining Standard Hazmat Employee trainingStandard Hazmat Employee training

General AwarenessGeneral Awareness Function-SpecificFunction-Specific SafetySafety Security Awareness Security Awareness In Depth SecurityIn Depth Security

AvailabilityAvailability(MU suggestion)(MU suggestion)

Very RestrictedVery Restricted Limited number of CopiesLimited number of Copies

ChangesChanges Require authorizationRequire authorization Require re-trainingRequire re-training

Access to PlansAccess to Plans

DISCUSSIONDISCUSSIONANDAND

QUESTIONSQUESTIONS

Thank YouThank You