HM-232

1. HM-232 Revised 5-30-2008

2. HM-232 RSPA, the Research and Special Programs Administration, has established new requirements under a final rule, HM-232, to enhance the security of hazardous materials transported in commerce.

3. HM-232 All shippers and carriers of hazardous materials must make sure hazmat employees receive training that includes a security component.

4. Security awareness training (Part 172, Subpart H) • Hazmat employees must receive training to make them aware of security risks associated with hazmat transportation, as well as ways to ensure hazardous materials are safe during the transportation process. • The security awareness training must also cover how to recognize and respond to possible security threats.

5. HM-232 Training Deadlines In-depth security training must be completed by December 22, 2003 for current employees. Training may be repeated as needed and as changes are made to the security plan. New employees must be trained within 90 days of employment.

6. Security Overview • The terrorist attacks of 9/11 changed the way hazardous material (HM) is handled and transported. It resulted in: • Heightened sense of awareness • Need for increased security • Communication of potential security risks to all HM employees • Required security awareness training

7. Awareness of security risks • Need for increased security • Examples of terrorist acts • Important to: • Have a heightened sense of awareness • Identify potential targets and security threats • Recognize security risks that may be present

8. Potential security threats • Potential targets and threats could include: • Gasoline or other flammable materials/gases • Poisons or materials poisonous by inhalation • Materials, that when mixed, become potential deadly weapons • Explosives

9. Potential security threats • Potential geographical targets may include: • Historical monuments • Public, state, federal buildings/sites • Water towers and reservoirs

10. Potential security threats • Potential geographical targets may include (continued): • Gas stations, refineries, and industrial locations • Churches, school, and hospitals • Train stations, bus terminals, and airports

11. Potential security threats • Company-specific targets and threats may include: • Access points, terminal gates, and entrances • Perimeters and fenced-in areas • Doorways and windows

12. Potential security threats • Company-specific targets and threats may include (continued): • Communication areas • Limited access and restricted areas • Physical facilities and equipment • Vehicles and inventory that could be used as weapons

13. Security risks on the road • Terrorist activities could include: • Cargo theft • Cargo contamination • Vehicle hijacking • Kidnapping • Bodily harm • Death

14. Security risks on the road • Additional geographical targets/locations: • Tunnels and bridges • Railroad tracks and switching areas • Lakes, rivers, and dams • High density population areas • Virtually anywhere HM could be ignited or detonated

15. Security risks on the road • Be on the lookout for suspicious activity/behavior associated with: • The planned route • Rest stops and truck stops • Maintaining visual contact with the load • Traffic lights and unplanned stops • Vehicles stopped along the road • People posing as authorities • Unlit areas

16. Security risks on the road • Typical driver checklist could include: • Verifying paperwork • Checking on emergency response information • Accepting only HM properly packaged, labeled, and marked for transport • Supervising loading and locking of trailer • Planning the quickest and safest route with minimum stops

17. Security risks on the road • Typical driver checklist could include (continued): • Staying alert, aware, and observant from start to finish • Securing stopped vehicle; never leaving it unattended • Keeping in touch with dispatcher/home base • Contacting authorities if threat is observed/encountered

18. Security risks on the road • Carriers could consider: • Establishing shipment tracking procedures • Having check points and check-in times en route • Providing a 24-hour number drivers can call • Keeping actual road time to a minimum • Installing locks and alarms

19. Suspicious activity • Points to remember: • It’s okay to be suspicious • Don’t ignore suspicious activity or behavior • It’s more important to report it than to have a potential threat or target become a reality • Suspicious activity should raise a red flag to well-trained employees

20. Suspicious activity • Closely watch and possibly report: • Unauthorized persons trying to access equipment or off-limit areas • Disgruntled employees • Anyone appearing to be extremely nervous, agitated or hiding something

21. Suspicious activity • Closely watch and possibly report (continued): • Anyone asking sensitive questions or requesting information when unauthorized to do so • Anyone without proper I.D. • Anyone possessing a weapon • Unfamiliar vehicles parked where they don’t belong

22. Enhancing your transportation security • Requires cooperation of everyone involved • Goes hand-in-hand with reducing security risks • Enhances transportation security by focusing on: • Personnel security • Facility security • En route security

23. Responding to alerts • When DHS raises or lowers the threat level: • Employees, temporary employees, and contractors will be expected to follow protocol introduced during formal training • Each department and employee will be instructed on additional roles and protocol for each threat level

24. Responding to alerts • When DHS raises or lowers the threat level: • Each department or area will have a point of contact • Employees will be expected to use the designated method of communication (e.g., cell phone, email, intranet, etc.) during the threat level

25. Responding to alerts • The U.S. Coast Guard has developed a tiered maritime security advisory system (MARSEC Levels), which parallels DHS codes: • This system applies to port facilities • Carriers, vendors, and visitors entering port facilities will be subject to more stringent security protocols during heightened alerts for a specific port

26. Responding to alerts • When a MARSEC level raises or lowers at a specific port facility: • Employees, temporary employees, and contractors (such as truckers) will be expected to follow protocols set up by the port facility

27. Responding to alerts • When a MARSEC level raises or lowers at a specific port facility: • Employees will be expected to use the designated method of communication (e.g., cell phone, email, intranet, etc.) during the threat level • Employees will be expected to follow customer security measures while on their site during alerts

28. Security Recommendations for Drivers Before the driver leaves • Must have been hazardous materials trained, tested, and certified by employer. • Must have proper identification. • Must have proper licenses, endorsements, or permits for hazardous materials. Must have proper shipping documents, such as hazardous materials shipping papers and emergency response information. • Know the route. • Know procedures for emergency situations. • Know who to contact in an emergency.

29. Security awareness training (Part 172, Subpart H) In addition, shippers and carriers of certain highly hazardous materials must develop and implement security plans, as well as provide in-depth security training to employees.

30. Security plans and in-depth security training (Part 172, Subpart H & I) The security plan must include an assessment of possible transportation security risks and appropriate measures to address the risks.

31. The security plan must be: • in writing and retained for as long as it remains in effect; • revised and updated as needed to reflect changing circumstances; and • made available to all employees responsible for implementing it.

32. At a minimum, a security plan must include the following: • Personnel security; • Unauthorized access; and • En route security. Hazmat shippers and carriers required to complete a security plan must do so by September 25, 2003.

33. The Security Plan Must Be: • in writing and retained for as long as it remains in effect; • revised and updated as needed to reflect changing circumstances; and • made available to all employees responsible for implementing it.

34. OTL-UPT Security Objectives Purpose To set forth policies and procedures for protecting company resources and consigned customer cargo from acts of terrorism, hijacking, theft, and/ or intentional destruction. Company resources include, but are not limited to its personnel, equipment, facilities, and electronic media.

35. OTL-UPT Employee Responsibilities Responsibility The Company’s Vice President of Risk Management is responsible for the overall coordination of the Company’s Security Plan. Each department head and CSC/facility manager is accountable for the proper and timely administration of this directive within his/her assigned area(s) of responsibility. A dispatched driver is responsible for strict adherence to the precautionary security guidelines set forth in this directive. These guidelines are designed to help safeguard a driver’s personal safety, as well as to protect other company resources and consigned customer cargo.

36. OTL-UPT The Organizational Security Structure The Company is totally committed to safeguarding the personal security of its employees and lease operators, and to protect all other company resources and consigned customer cargo from acts of terrorism, hijacking, theft, and/or intentional destruction.

37. OTL-UPT Security PlanPersonnel Security The Company’s Manager of Driver Resources shall ensure that comprehensive and thorough criminal background checks and previous employment verifications are completed on all applicants seeking employment or lease operator contracts with the Company. Driver applications shall be processed and evaluated in accordance with the provisions of Company Policies HR-019-000-000. The Manager of Driver Resources will ensure personnel files are properly maintained in a secure and confidential manner.

38. OTL-UPT Security PlanSecurity Awareness Training Security Awareness Training - At least annually, each CSC/facility manager shall ensure that all assigned HAZMAT Employees view the safety video titled, “Truck Driver and Cargo Security”, or its corporate approved equivalent.

39. OTL-UPT Security PlanSecurity Awareness Training In addition, each HAZMAT employee shall annually read this directive in order to meet the federally mandated HAZMAT training requirements. A HAZMAT Employee is defined as any employee who performs any task covered by the Hazardous Materials Regulations.

40. OTL-UPT Security PlanSecurity Awareness Training The initial viewing of the training video shall be a mandatory component of company Safety and Security Orientation. In addition, each department head and terminal/facility manager will ensure that all assigned employees and lease operators have read this directive.

41. OTL-UPT Security PlanSecurity Awareness Training Certification of Security Awareness Training, documenting completion of this task shall be executed and forwarded to the Company’s Director of Education. A copy will be maintained on file by the department or CSC/facility for a minimum of one year after completion of this security awareness training.

42. OTL-UPT Security PlanEn Route Security Secure Routing of Hazardous Material Shipments 1. No company employee shall accept new hazardous materials business from an unknown broker or potential customer without thoroughly validating the authenticity of the tendered business.

43. OTL-UPT Security PlanEn Route Security 2. Driver and cargo security considerations shall be factored into the determination of each specified transportation route. Such considerations shall include, but not be limited to the avoidance, when possible, of bridges, tunnels, and densely populated areas.

44. OTL-UPT Security PlanEn Route Security 3. Not withstanding mandated hours of service regulations, concerted efforts shall be made by CSC and Fleet Control Center (FCC) operational personnel to minimize in-transit driver downtime. The objective of this security measure is to help ensure that a driver, and his/her assigned equipment/cargo have minimal physical exposure to being targeted for acts of terrorism, hijacking, theft, and/or intentional destruction.

45. OTL-UPT Security PlanEn Route Security 4. The Company Fleet Control Center (FCC) and or CSC Manager shall monitor the overnight parking or staging of all dispatched long-haul tractors.

46. OTL-UPT Security PlanEn Route Security 5. During a long-haul trip, the assigned driver(s) shall be responsible for maintaining proper communications, with the Fleet Control Center (FCC) and or CSC. Such communications shall be in accordance with instructions issued to the driver(s) by the Fleet Control Center (FCC) and or CSC as a minimum; such routine contact by a driver shall be made every 12 hours. However, a driver shall immediately report to the Fleet Control Center (FCC) and or CSC each potential or actual security threat, safety incident, equipment maintenance problem, or operational issue that is encountered by the driver.

47. OTL-UPT Security PlanEn Route Security The Fleet Control Center (FCC) shall keep the driver’s domiciled CSC informed regarding the status of a long-haul trip, to include its transportation routing and the estimated return date and time of the assigned driver and equipment.

48. Drivers and Cargo Security 1. A driver shall conduct a thorough pre-trip vehicle inspection before each trip. Furthermore, a walk around vehicle inspection and security check must be completed by the driver after each loading and unloading of cargo, as well as after each time he/she takes a rest break. Any and all noted problems or concerns shall be addressed prior to the unit continuing in operation.

49. Drivers and Cargo Security 2. While on a dispatched load, a driver shall not discuss information related to his/her consigned cargo, planned transportation route, or product pickup and delivery schedule with any person(s) other than an authorized company employee.

50. Drivers and Cargo Security 3. A driver shall shut down and secure his/her assigned tractor when it is not in operation. Its doors must be locked, windows closed, and the unit’s ignition key removed.