Department Of Transportation: Registration and Security Plan

by Sarah Mueller, Senior Consulting Safety Officer, Safety Partners, Inc.
Kim Caserta, Consulting Safety Officer, Safety Partners, Inc.
Denise Aronson, President, Safety Partners, Inc.

In the wake of the September 11, 2001 attacks on the Pentagon and New York City and global transportation threats and acts of terrorism, federal and state law enforcement and regulatory agencies heightened their concern about the secure and safe transport of hazardous materials. The concern of carriers, shippers, consignees, and emergency responders increased as well.

Transporting hazardous materials presents serious challenges that hazardous materials stored at fixed facilities don't. They are:

1. Often transported in very large quantities
2. Vulnerable to theft, interception, sabotage, detonation, or release
3. Accidents or intentional acts, especially in populated areas, can result in injuries and loss of life, as well as damage to property and the environment

This article addresses U.S Department of Transportation (DOT) registration requirements and security plans. The fee you pay when registering with the DOT funds grants that are then used for emergency response planning and training. The security plan helps you assess your organization's hazardous materials transportation vulnerabilities and how to address them. If you are required to register with the DOT, then you are also required to have a written security plan.

DOT Registration

Under Title 49 CFR Part 107, Subpart G (107.601-107.620), certain offerors and transporters of hazardous materials, including hazardous waste, are required to file an annual registration with the United States Department of Transportation Pipeline and Hazardous Materials Safety Administration. More specifically, 49 CFR 107.601(a) (6) requires a registration for any quantity of hazardous material that requires placarding under the provisions of 49 CFR Part 172, Subpart F. 49 CFR 172.504 requires placarding of any transport vehicle or freight container which contains more than 454 kg (1001 pounds) aggregate gross weight of hazardous materials covered by table 2 of paragraph (e) of this section or any amount of hazardous materials covered by table 1 of paragraph (e) of this section.

Companies may register for one to three years. The registration fee varies based on business size and non-profit status.

DOT Security Plan

In addition to registering with the DOT, 49 CFR 172.800(b) requires each person who offers for transportation or transports one of more of the hazardous materials listed in 172.800(b)(1-7) to develop and implement a security plan in compliance with Subpart I. The security plan must include an assessment of possible transportation security risks for shipments of the hazardous materials covered under this regulation, and appropriate measures to address the assessed risks. At a minimum, the following elements must be included:

1. Personnel security – measures to confirm information provided by job applicants hired for positions that involve access or handling of hazardous materials.
2. Unauthorized access – measures to address the assessed risk that unauthorized persons gain access to the hazardous materials or transport conveyances being prepared for shipment.
3. En route security – measures to address the assessed security risks of shipments of hazardous materials covered by the plan en route from origin to destination.

The U.S. DOT Research and Special Programs Administration provides a tool entitled Enhancing Security of Hazardous Materials Shipments Against Acts of Terrorism or Sabotage Using RSPA's Risk Management Self-Evaluation Framework (RMSEF) that can be used as a guide to aide in the development of security plans.

Security plans are not meant to sit on a shelf to gather dust. They must be revised and updated as needed to reflect changing circumstances, such as revised regulations, if the plan fails, or if new security measures are incorporated.

For more information or to register online, visit: http://www.phmsa.dot.gov/hazmat/registration.

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Safety Partners efficiently and cost-effectively implements hands-on environmental, health, and safety (EHS) programs at emerging life sciences companies. Safety Partners tailors its programs to each client's unique science, processes, procedures, and facilities, while reducing program implementation burdens. Its expertise is unmatched, clocking over 85,000 hours at over 120 New England life sciences firms.