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

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

49 CFR Applicability Applies to each “person” who offers for transport in commerce or transports in commerce, one of the following: n Highway Route-Controlled Class 7 n More than 25 kg of Division 1.1, 1.2, 1.3 n More than 1 L per package PIH Zone A n Bulk shipments of 3,500 gal for liquids and 468 cubic feet for solids 5. Non-bulk shipments of 5,000 lbs gross wt of one hazard class requiring placarding 6. A select agent or toxin regulated by CDC 7. A quantity of hazardous material that requires placarding

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

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

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

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

Organization of Plans as recommended by MU Statement of Purpose Statement of Purpose Scope of Plan Scope of Plan Security Plan Elements (DOT required components) Security Plan Elements (DOT required components) Availability Availability

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

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

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

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

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

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

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

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

DISCUSSION AND QUESTIONS Thank You