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

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New dot security regulations

NEW DOTSECURITY REGULATIONS

Russell S. Hanson

Peter C. Ashbrook

U of Missouri-Columbia

November 13, 2003


49 cfr 172 subparts

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


49 cfr 172 800 applicability
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


Mu ehs security plans
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


49 cfr 172 704 amended training requirements
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


    Security training
    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)


  • 49 cfr 172 802 components of a security plan
    49 CFR 172.802Components of a Security Plan

    • Personnel Security

    • Unauthorized Access

    • En Route Security

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


    Organization of plans as recommended by mu
    Organization of Plansas recommended by MU

    • Statement of Purpose

    • Scope of Plan

    • Security Plan Elements (DOT required components)

    • Availability


    Statement of purpose mu suggestion
    Statement of Purpose(MU Suggestion)

    • Commitment to safety

    • Commitment to security of…

      • Faculty

      • Staff

      • Students

      • General Public


    Scope of plan mu suggestion
    Scope of Plan(MU Suggestion)

    • Type of shipment covered by the plan

      • Origin

      • Destination

      • Conveyance

    • The Plan is further restricted to the Transportation Event


    Transportation event mu suggestion
    Transportation Event(MU Suggestion)

    • Example Event types:

      • Loading

      • Unloading

      • Driving

    • MU responsibilities

      • EHS

      • Other MU Departments, if any

  • Non-MU Driver responsibilities

    • Where applicable


  • Security plan elements dot required
    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


    Security plan elements dot required1
    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


    Security plan elements dot required2
    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


    Security plan elements required by dot but not necessarily in security plan itself
    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


    Availability mu suggestion
    Availability(MU suggestion)

    • Very Restricted

      • Limited number of Copies

    • Changes

      • Require authorization

      • Require re-training

    • Access to Plans


    Discussion and questions

    DISCUSSIONANDQUESTIONS

    Thank You


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