NEW DOT SECURITY REGULATIONS

1. NEW DOTSECURITY REGULATIONS Russell S. Hanson Peter C. Ashbrook U of Missouri-Columbia November 13, 2003

2. Added by HM-232 Effective Date: 3/25/03 Comply by: 9/25/03 49 CFR 172 Subparts • A - GENERAL • B - TABLE OF HAZARDOUS MATERIALS AND SPECIAL PROVISIONS • C - SHIPPING PAPERS • D - MARKING • E - LABELING • F - PLACARDING • G - EMERGENCY RESPONSE INFORMATION • H - TRAINING • I - SECURITY PLANS • APPENDICES

3. 49 CFR 172.800Applicability Applies to each “person” who offers for transport in commerce or transports in commerce, one of the following: • Highway Route-Controlled Class 7 • More than 25 kg of Division 1.1, 1.2, 1.3 • More than 1 L per package PIH Zone A • Bulk shipments of 3,500 gal for liquids and 468 cubic feet for solids • Non-bulk shipments of 5,000 lbs gross wt of one hazard class requiring placarding • A select agent or toxin regulated by CDC • A quantity of hazardous material that requires placarding

4. MU EHS Security Plans • HW Shipments • Separate Plan for each Disposal Service Vendor • Rad Waste Pick ups • Plan currently limited to MU Campus • Yellow-III Rad Package Deliveries • Draft Plan as a contingency • Other Plans developed as needed • e.g. select agents

5. 49 CFR 172.704(Amended) Training Requirements • What is Required? • General Awareness/Familiarization Training • Function-specific Training • Safety Training • 172.704(a)(1) – (3) • Security Awareness Training • 172.704(a)(4) • In-Depth Security Training • 172.704(a)(5) NEW

6. SECURITY TRAINING • Security Awareness Training • Required for all hazmat employees • Previously trained hazmat employees need not be trained until they receive recurrent training (by 3/24/2006) • In-Depth Security Training • Only required when the hazmat employer must have a Security Plan (within 90 days of plan development or employee hire)

7. 49 CFR 172.802Components of a Security Plan • Personnel Security • Unauthorized Access • En Route Security DOT web site: hazmat.dot.gov/hmt_security.htm

8. Organization of Plansas recommended by MU • Statement of Purpose • Scope of Plan • Security Plan Elements (DOT required components) • Availability

9. Statement of Purpose(MU Suggestion) • Commitment to safety • Commitment to security of… • Faculty • Staff • Students • General Public

10. Scope of Plan(MU Suggestion) • Type of shipment covered by the plan • Origin • Destination • Conveyance • The Plan is further restricted to the Transportation Event

11. Transportation Event(MU Suggestion) • Example Event types: • Loading • Unloading • Driving • MU responsibilities • EHS • Other MU Departments, if any • Non-MU Driver responsibilities • Where applicable

12. Security Plan Elements(DOT Required) • Personnel Security • Background Screening (Human Resources) Notes: • All of these individuals are designated as hazmat employees • CDL for Driver, if applicable

13. Security Plan Elements(DOT Required) • Unauthorized Access • Start of Transportation Event • Security Person • How to respond to unauthorized persons • Access concerns during Loading and Unloading Events addressed in this section • Access concerns during Driving Events are addressed in the En Route Security section • Conclusion of Transportation Event

14. Security Plan Elements(DOT Required) • En Route Security • MU Driving • Prior to Departure • En Route Security provided by MU • EHS • Police (MUPD, Other) • Non-MU Driving • Prior to Departure • After Departure • En Route Security provided by Driver’s Company

15. Security Plan Elements(Required by DOT, but not necessarily in Security Plan, itself) • Training • Standard Hazmat Employee training • General Awareness • Function-Specific • Safety • Security Awareness • In Depth Security

16. Availability(MU suggestion) • Very Restricted • Limited number of Copies • Changes • Require authorization • Require re-training • Access to Plans

17. DISCUSSIONANDQUESTIONS Thank You