The U.S. Department of Transportation (DOT), through its hazardous material regulations (HMRs), specifies requirements for the safe transportation of hazardous materials in commerce by rail, aircraft, vessel, and motor vehicle. DOT has general requirements for the loading, unloading, handling, and storage of explosives and hazardous materials as well as specific modal requirements.

DOT has requirements at 49 CFR 177 that are specific to the transportation of hazardous materials on public highways by private, common, or contract carriers that are in addition to the other applicable requirements. These requirements pertain to:

  • Training
  • Shipping papers
  • Emergency situations and accidents
  • Loading and unloading
  • Segregation and separation of materials
  • Carrying passengers for hire

Here’s a security checklist you can use to double-check your hazmat operations.

Personnel Security

  • Encourage your employees to report suspicious incidents or events.
  • Implement routine security inspections.
  • Convene regular employee/management meetings on security measures and awareness.
  • Make sure all employees handling or transporting hazardous materials have adequate communication devices in case of emergency. Test these systems.
  • If you have a management crisis team, verify their 24/7 contact information and place them on “ready alert.”
  • Ensure that all employees have proper and up-to-date identification.
  • Ensure that company personnel monitor news and other information sources for events or changes in conditions and respond as appropriate.

Facility Security

  • Cooperate with federal or local law enforcement officials concerning security checks or safety checks.
  • Restrict the availability of information related to your facility and employees, and the materials you handle.
  • Restrict access to a single entry or gate. Control who enters and leaves your facility, if possible. Require visitors to show photo identification and have someone accompany visitors at all times.
  • Add security guards and increase off-hours patrols by security or law enforcement officials.
  • Reduce your internal tolerance for “security anomalies,” such as overdue or missing vehicles, perimeter of physical plant intrusions, unverified visitors, evidence of tampering, and the like.
  • Install additional security systems on areas containing hazardous materials, if needed.
  • Do not preload hazardous materials shipments.
  • Require employees to display identification cards or badges while at the facility.
  • Conduct spot checks of personnel and vehicles.
  • Test your emergency response communications systems.
  • Upgrade security procedures for pick-ups and deliveries. Verify all paperwork and require pick-up and delivery appointments from known vendors. Require pick-up drivers to provide driver’s name and vehicle number—confirm with vendor. Accept deliveries in designated areas only.
  • Confirm legitimacy of new vendors through listings in phone book or industry publications, websites, or references.
  • Secure hazardous materials in locked buildings or fenced areas. Have a sign-out system for keys.
  • Secure valves, manways, and other fixtures on transportation equipment when not in use. Secure all rail, truck, and barge containers when stored at your location.
  • Use tamper-resistant or tamper-evident seals and locks on cargo compartment openings.
  • Maintain current inventories of on-site hazardous materials and check accounts for shortages or discrepancies.

En Route Security

  • Use carrier safety ratings, assessments, safety surveys, or audits and ask the carrier to provide information on security measures it has implemented.
  • Verify that the carrier has an appropriate employee hiring and review process, including background checks, and an ongoing security training program.
  • Verify identity of carrier or driver before hazardous materials loading. Ask driver for photo identification and compare with information provided by carrier.
  • Ask the driver to tell you the name of the consignee and the destination for the material, and confirm with your records before releasing shipments.
  • Identify preferred and alternate routing, including acceptable deviations. Make sure routing complies with local routing restrictions.
  • If possible, alternate routes to frequent destinations.
  • Minimize exposure in downtown or heavily populated areas, and expedite the shipment to the final destination.
  • Minimize stops en route; if you must stop, select locations with adequate lighting on well-traveled roads and avoid high crime or dangerous areas.
  • If materials are stored during transportation, make sure storage facilities are secure.
  • Train drivers how to avoid hijackings or theft of property–keep vehicles locked when parked and avoid conversation on open channels or with strangers about route, cargo, and destinations.
  • Consider an escort or guard for high-hazard shipments (e.g., explosives, radioactive materials, or inhalation hazard toxics).
  • Consider using advanced technology to track or protect your cargo en route to their destination (e.g., satellite tracking systems, antitheft systems for trailers and tractors, and surveillance systems). GPS tracking systems should relay updates more frequently.
  • Install tamper-proof seals on all valves and package or container openings.
  • Implement a system for a customer to alert the shipper if a hazardous materials shipment is not received when expected.
  • When products are delivered, check the carrier’s identity with shipping documents provided by the shipper.
  • Get to know your customers and their hazardous materials programs. If you suspect you shipped or delivered a hazardous material to someone who may intend to use it for a criminal activity, notify your local FBI office or local law enforcement officials.
  • Report any suspicious or unusual behavior or incidents to your local law enforcement officials.

For more information or assistance with your Environmental and Health & Safety regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599.