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Transportation and Facility
Security

Pursuant to 49 CFR Part 172.704
Why Now?
♦ General security
♦ Security of hazardous materials
♦ Workplace violence
♦ After 9-11
Regulatory Requirements
♦ 49 CFR Part 179           ♦ En route security
♦ Administrative            ♦ Training and
  responsibilities            information
♦ Suspicious activity       ♦ Conduct a security
♦ Hazmat personnel            risk assessment
  screening
♦ Information security
♦ Security inspections
♦ Facility access control
Administrative Responsibilities
♦ VP/GM and Branch Managers are
 responsible for:

  – Establishing and communicating the overall
    security goals of the organization
Administrative Responsibilities
          (Continued)
♦ Managers and Supervisors are responsible
 for:
  – Being fully knowledgeable of the security
    issues and concerns of their department,
    area(s), and employees
  – Providing detailed information on system
    operations including:
     • Daily work processes, activities, and identifying
       potential security vulnerabilities
Administrative Responsibilities
          (Continued)
♦ Employee responsibilities:
  – Employees are responsible for adhering and
    conforming to all security-related work
    activities, processes, and procedures.
  – Employees are also encouraged to provide
    feedback and suggestions for improving the
    security plan.
Suspicious Activity
♦ Employees have the responsibility to themselves and to the
  company to observe and report suspicious activity
♦ Suspicious activity includes (but is not limited to):
   – Unidentified person(s) attempting to gain access to property,
     equipment, or facilities
   – Unidentified person(s) in any area of the company, office, yard, or
     parking lot
   – Any unescorted visitor anywhere in the building or wandering
     around facility property
   – Any person (employee or otherwise) who appears to be hiding
     something, is acting nervous, anxious, or secretive
   – Any employee or visitor making unusual or repeated requests for
     sensitive or important company documents or information
Suspicious Activity
              (Continued)
♦ Suspicious activity includes (but is not limited to):
   – Any person asking an employee to make an
     unauthorized pickup/delivery
   – Any person loitering outside a company facility
     or premises
   – Any person claiming to be a representative of a
     utility company but cannot produce appropriate
     identification
   – Any person carrying a weapon, e.g., a gun,
     knife, etc.
Reporting Suspicious Activity
♦ Employees have the responsibility to
  themselves and to AC&S – HTP to report
  any suspicious activity
♦ Use common sense when determining
  suspicious activity
♦ Report suspicious activity immediately to
  your supervisor and/or next level manager
Hazmat Personnel Screening
♦ The facility administrator will will verify
  information provided by hazmat employees
  including:
  – Previous employment history
  – Proof of citizenship
  – Driving record
  – Driver qualifications
    (as defined in company policy)
  – Alcohol screening
Information Security
♦ All information (hard copy or electronic) shall be
  restricted to employees on a “need-to-know basis”
   – Work/load assignment sheets will be sequentially
     numbered and secured
   – Access to load information must be limited to operation
     personnel only
   – For security purposes:
      • The packing slip or bill of lading number must be clearly
        communicated
      • Trailer numbers on all work assignments are verified
      • Shippers packing slip or bill of lading number is verified
   – In the event a trailer must be staged overnight, all load
     related documentation will be secured in an office and
     not in the vehicle
Security Inspections
♦ The security plan requires specific security
  inspections of the following:
  –   Fences
  –   Gates
  –   Exterior doors
  –   Perimeter
♦ Inspections forms have been revised to
  include the above checks
Facility Access Control
♦ Main entrance, e.g. point of entry
   – Warehouse office
   – Front office
♦ Non-AC&S/HTP personnel on company property:
   – Visitor requirements
   – Contractor requirements
   – Outside driver requirements
♦ Employee and visitor parking
♦ Loitering on company property
En-Route Security
♦ Qualifying motor carriers
   – Approved hazmat carriers list
   – Verify the identity of the driver and motor carrier
   – Ask the driver for the name of the consignee and
     destination
♦ Point of origin security
   – Drivers shall check in with appropriate personnel and
     provide identification (if requested) upon arrival at
     pick-up/drop-off location
   – Drivers will follow all safety and/or security
     instructions at the customer facility as requested
En-Route Security
                   (continued)
♦ Shipper Load and Count
   – In the event a driver is scheduled to pick-up a
     trailer pre-loaded with hazmat, the driver shall
     verify the following:
      •   The loads shipping papers
      •   Seal numbers (if applicable)
      •   Trailer number
      •   If a discrepancy is found between the cargo and bill
          of lading or shipping manifest, the driver shall
          contact their supervisor for instructions immediately
En-Route Security
                 (continued)
♦ En-Route security procedures
  – Drivers will coordinate with their
    supervisor/dispatcher to prepare and execute a
    routing sheet for all hazmat movements
    including;
      • Routes or schedules to avoid highly populated areas,
        bridges, and tunnels when possible
      • Fueling/break locations and times
      • Times of daily/routine check calls
      • Estimated times of arrival to stop offs and return
En-Route Security
                  (continued)
♦ En-route driver security procedures:
   – Drivers are prohibited from discussing information
     related to their load, route, or delivery schedule with
     any person other than authorized company officials
   – Report any suspicious activity to your supervisor
     immediately
   – Drivers must make all reasonable precautions to
     prevent damage or theft of hazmat while in transit
   – Inspect your vehicle after every stop for evidence of
     tampering
   – Park only in safe and authorized areas
   – Drivers will lock their doors and keep windows closed
     while in urban areas
Required Documents
             and Equipment
♦ Required Documents:
  – Proof of insurance
  – Copy of Federal DOT Hazmat registration
  – Copy of CHP (or applicable state) Hazmat
    license
  – Copy of applicable DOT exemptions
  – Vehicle registration
  – Accident reporting kit
     • All of the above should be kept together and easily accessible
Required Documents
              and Equipment
♦ Required Equipment:
  –   Drum overpak
  –   Case overpak
  –   Drain cover
  –   Spill socks
  –   Spill pads
      • All of above equipment can be placed inside the overpak drum
Conclusion
♦ A hazmat transportation security plan is
  required by DOT
♦ Security is common sense
♦ Everyone is responsible for ensuring
  hazmat is kept safe and secure
♦ Additional company polices and procedures
  already in place

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Transportation And Facility Security

  • 2. Why Now? ♦ General security ♦ Security of hazardous materials ♦ Workplace violence ♦ After 9-11
  • 3. Regulatory Requirements ♦ 49 CFR Part 179 ♦ En route security ♦ Administrative ♦ Training and responsibilities information ♦ Suspicious activity ♦ Conduct a security ♦ Hazmat personnel risk assessment screening ♦ Information security ♦ Security inspections ♦ Facility access control
  • 4. Administrative Responsibilities ♦ VP/GM and Branch Managers are responsible for: – Establishing and communicating the overall security goals of the organization
  • 5. Administrative Responsibilities (Continued) ♦ Managers and Supervisors are responsible for: – Being fully knowledgeable of the security issues and concerns of their department, area(s), and employees – Providing detailed information on system operations including: • Daily work processes, activities, and identifying potential security vulnerabilities
  • 6. Administrative Responsibilities (Continued) ♦ Employee responsibilities: – Employees are responsible for adhering and conforming to all security-related work activities, processes, and procedures. – Employees are also encouraged to provide feedback and suggestions for improving the security plan.
  • 7. Suspicious Activity ♦ Employees have the responsibility to themselves and to the company to observe and report suspicious activity ♦ Suspicious activity includes (but is not limited to): – Unidentified person(s) attempting to gain access to property, equipment, or facilities – Unidentified person(s) in any area of the company, office, yard, or parking lot – Any unescorted visitor anywhere in the building or wandering around facility property – Any person (employee or otherwise) who appears to be hiding something, is acting nervous, anxious, or secretive – Any employee or visitor making unusual or repeated requests for sensitive or important company documents or information
  • 8. Suspicious Activity (Continued) ♦ Suspicious activity includes (but is not limited to): – Any person asking an employee to make an unauthorized pickup/delivery – Any person loitering outside a company facility or premises – Any person claiming to be a representative of a utility company but cannot produce appropriate identification – Any person carrying a weapon, e.g., a gun, knife, etc.
  • 9. Reporting Suspicious Activity ♦ Employees have the responsibility to themselves and to AC&S – HTP to report any suspicious activity ♦ Use common sense when determining suspicious activity ♦ Report suspicious activity immediately to your supervisor and/or next level manager
  • 10. Hazmat Personnel Screening ♦ The facility administrator will will verify information provided by hazmat employees including: – Previous employment history – Proof of citizenship – Driving record – Driver qualifications (as defined in company policy) – Alcohol screening
  • 11. Information Security ♦ All information (hard copy or electronic) shall be restricted to employees on a “need-to-know basis” – Work/load assignment sheets will be sequentially numbered and secured – Access to load information must be limited to operation personnel only – For security purposes: • The packing slip or bill of lading number must be clearly communicated • Trailer numbers on all work assignments are verified • Shippers packing slip or bill of lading number is verified – In the event a trailer must be staged overnight, all load related documentation will be secured in an office and not in the vehicle
  • 12. Security Inspections ♦ The security plan requires specific security inspections of the following: – Fences – Gates – Exterior doors – Perimeter ♦ Inspections forms have been revised to include the above checks
  • 13. Facility Access Control ♦ Main entrance, e.g. point of entry – Warehouse office – Front office ♦ Non-AC&S/HTP personnel on company property: – Visitor requirements – Contractor requirements – Outside driver requirements ♦ Employee and visitor parking ♦ Loitering on company property
  • 14. En-Route Security ♦ Qualifying motor carriers – Approved hazmat carriers list – Verify the identity of the driver and motor carrier – Ask the driver for the name of the consignee and destination ♦ Point of origin security – Drivers shall check in with appropriate personnel and provide identification (if requested) upon arrival at pick-up/drop-off location – Drivers will follow all safety and/or security instructions at the customer facility as requested
  • 15. En-Route Security (continued) ♦ Shipper Load and Count – In the event a driver is scheduled to pick-up a trailer pre-loaded with hazmat, the driver shall verify the following: • The loads shipping papers • Seal numbers (if applicable) • Trailer number • If a discrepancy is found between the cargo and bill of lading or shipping manifest, the driver shall contact their supervisor for instructions immediately
  • 16. En-Route Security (continued) ♦ En-Route security procedures – Drivers will coordinate with their supervisor/dispatcher to prepare and execute a routing sheet for all hazmat movements including; • Routes or schedules to avoid highly populated areas, bridges, and tunnels when possible • Fueling/break locations and times • Times of daily/routine check calls • Estimated times of arrival to stop offs and return
  • 17. En-Route Security (continued) ♦ En-route driver security procedures: – Drivers are prohibited from discussing information related to their load, route, or delivery schedule with any person other than authorized company officials – Report any suspicious activity to your supervisor immediately – Drivers must make all reasonable precautions to prevent damage or theft of hazmat while in transit – Inspect your vehicle after every stop for evidence of tampering – Park only in safe and authorized areas – Drivers will lock their doors and keep windows closed while in urban areas
  • 18. Required Documents and Equipment ♦ Required Documents: – Proof of insurance – Copy of Federal DOT Hazmat registration – Copy of CHP (or applicable state) Hazmat license – Copy of applicable DOT exemptions – Vehicle registration – Accident reporting kit • All of the above should be kept together and easily accessible
  • 19. Required Documents and Equipment ♦ Required Equipment: – Drum overpak – Case overpak – Drain cover – Spill socks – Spill pads • All of above equipment can be placed inside the overpak drum
  • 20. Conclusion ♦ A hazmat transportation security plan is required by DOT ♦ Security is common sense ♦ Everyone is responsible for ensuring hazmat is kept safe and secure ♦ Additional company polices and procedures already in place