HM-232 Revised 5-30-2008

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.

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

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.

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.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.

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.

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.

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.

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.

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.

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.

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.

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.

OTL-UPT Security Plan Personnel 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.

OTL-UPT Security Plan Security 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.

OTL-UPT Security Plan Security 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.

OTL-UPT Security Plan Security 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.

OTL-UPT Security Plan Security 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.

OTL-UPT Security Plan En 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.

OTL-UPT Security Plan En 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.

OTL-UPT Security Plan En 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.

OTL-UPT Security Plan En 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.

OTL-UPT Security Plan En 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.

OTL-UPT Security Plan En 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.

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.

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.

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.

Drivers and Cargo Security 4. A tractor and/or trailer shall not be left unattended by a driver without proper security safeguards being taken. A unit will only be parked or staged in a company-authorized location that has a high level of lighting, visibility, and security. No mobile equipment operated by the Company shall be parked on or within 5 feet of the traveled portion of a public street or highway, except for brief periods when the necessities of operation require the vehicle to be parked and make it impractical to park the vehicle in any other Place.

Drivers and Cargo Security Furthermore, said equipment shall not be parked or staged on private property (excluding premises of a fueling or eating facility) without the knowledge and consent of the Company, and the person, who is in charge of the property, and aware of the nature of the hazardous material(s) /the trailer contents.

Drivers and Cargo Security 5. Each driver shall remain aware, alert, and observant of his/her surroundings. Any suspicious act(s) that is observed should be immediately reported by the driver to his/her CSC or the Fleet Control Center (FCC). Immediate reporting to law enforcement authorities can be accomplished by telephoning (911).

Drivers and Cargo Security 6. A driver, who believes that an act of terrorism, hijacking, theft, and/or the intentional destruction of his/her assigned equipment is or may be in progress should attempt to keep the tractor/trailer moving in a safe and prudent manner. Such movement should continue until the attempted act has ceased and/or law enforcement authorities have been notified. However, the driver retains the right to exercise good judgment, as to whether to stop or keep the unit moving based on the degree of perceived threat to his/her personal safety.

Facility and Yard Security Each CSC/facility manager shall ensure that the following security measures are established and maintained for his/her assigned facility and equipment.

Facility and Yard Security 1. No unauthorized or unescorted visitor(s) shall be allowed to venture for any reason or at anytime beyond the terminal or facility’s reception area. 2. All tractor ignition keys that are not in-use will be secured in a locked key safe. Such a safe will be locked at all times, except when a key(s) is needed or is being returned to the safe.

Facility and Yard Security 3. Terminal facility yard checks will be conducted by designated personnel at a frequency rate of not less than once per day. As designated in writing by the Company’s Vice President of Risk Management, in consultation with the Chief Operating Officer, a CSC with a high-risk security exposure may be required to conduct more frequent yard checks, to include after hours and on weekends, holidays.

Facility and Yard Security Each yard check will be documented to depict the following information: a. The date and time of the yard check; b. Loaded trailer identification numbers; c. Empty trailer identification numbers; d. All parked/idle tractor identification numbers.

Facility and Yard Security All assigned mobile equipment shall be accounted for by the CSC/facility. Any tractor, trailer or other vehicle appearing on the yard which cannot be identified shall be physically and cautiously inspected and investigated. Any tractor and or trailer shown as being at the terminal/facility, but not accounted for during the yard check shall be immediately addressed and followed-up on in order to determine its current location and status via the use of the applicable loading planning records. Any unauthorized person(s) or vehicle(s) discovered during a yard check shall be reported to local law enforcement or to the appropriate company official(s).

Facility and Yard Security 4. Loaded Haz-Mat trailers shall not be parked or left unattended at a terminal/facility or any other location without the prior approval of the Company’s Vice President of Operations, the applicable Area Manager, or a Fleet Control Center (FCC) supervisor. All loaded trailers parked or staged at a CSC/facility shall be positioned in direct view of the CSC/facility’s operations center, or visually monitored via the use of video camera(s).

Facility and Yard Security Dropped loaded trailers will be parked or staged in compliance with company policy.

Electronic Media Security The security of electronic media and equipment, as well as its use within the Company shall be in accordance with the provisions of Company Policy Manual.

Actions to take in the event of a Security Breach Any suspicious actives, any report of a security problem or any questions concerning the security of equipment, building, Hazardous Material or personnel should be reported to the VP of Risk Management at 800-777-8265.