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FMCSA SECURITY TALKING POINTS

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Field officials with the Federal Motor Carrier Safety Administration will be reviewing security measures with motor carriers and shippers that may be the target of terrorist attack. Our mission: To increase the level of awareness of hazardous materials carriers to terrorist threats. The FMCSA field staff will be providing information in the form of recommendations and suggestions, except those regulatory requirements affecting the actual movement of hazardous materials. Highlights of the Security Talking Points are outlined below. These recommendations may not apply to all carriers, based on their size and scope of operation. Additionally, this list is not all-inclusive and will be changed based on future priorities to address terrorist threats.

OPENING INTERVIEW

  • Explain the reason for the visit.
  • This information is being offered as suggestions and recommendations. Except where noted, the security measures being discussed are not required by DOT regulation.
  • Some of the information may not be appropriate for all operations, particularly small operations.
  • Where possible, discuss some of the Suspicious Activity Reports that have been generated as a result of the SSVs that have already been conducted.
  • Emphasize that the security talking points should be considered in the hiring and training of all employees, not just drivers.

GENERAL SECURITY INFORMATION

  • Recommend to the carrier that a security plan be developed and implemented. It should include:
    • Personnel Security
    • Hazardous Materials and Package Control
    • En Route Security
    • Technical Innovations
    • Management Prerogatives
    • Communications
    • Reassessment Based Upon Current Conditions
  • Recommend that management encourage input and participation in the development and implementation of the company's security program.

PERSONNEL SECURITY

  • Discuss the fact that any employee could pose a security risk.
  • Implement method for security identification (i.e., ID badges). Identification should include the employee's name, the company name, the employee's picture, and a phone number where the employee's identification can be confirmed. Companies should establish systems to control security identification of employees leaving the company.
  • Review the list of drivers and request the required number of driver qualification files for review.
  • Ensure that the carrier is complying with the investigation and inquiry requirements of 49 CFR 391.23. Discuss with the company official any additional checks made, such as criminal background checks, personal reference checks, credit checks, etc.
  • When reviewing the contents of the driver qualification files, particular attention should be given to:
    • Gaps in employment
    • Frequent job shifts
    • All names used by the applicant
    • Type of military discharge
    • Citizenship
    • Present and prior residence information
    • Personal references
    • Criminal history
  • Verify compliance with the Immigration Reform and Control Act of 1986, in that I-9 forms are properly completed and maintained for all employees.
  • Determine if the company utilizes face-to-face interviews of prospective employees, to obtain information that will help to appraise personality, character, motivation, honesty, integrity, and reliability.
  • Any information or suspicious activity discovered during the review of these files should be reported immediately to your SD/DA for possible referral to the local FBI office.

HAZARDOUS MATERIALS AND PACKAGE CONTROLS
Security enhancements that might be considered:

  • Are the facility grounds adequately lighted?
  • Are hazardous materials located in a secure area?
  • Are transport vehicles located in a secure area?
  • Is the access to hazardous materials limited and/or monitored (sign-in/sign-out)?
  • Consider requiring employee identification cards/badges.
  • Consider other protective measures, such as security alarms, video surveillance, security services, etc.
  • Consider if a guard force is appropriate (DOD Shipments, poisonous by inhalation hazard materials, radioactive materials, DOE shipments, other).
  • Require records for removal of HM from secure locations.
  • Reinforce with employees the importance of remaining aware of their surroundings at all times.
  • Recommend standard procedures for control of HM packages, educating all employees on package control measures. Post procedures prominently at appropriate locations.
  • Know whom you are dealing with, including shippers, receivers and vendors that service your facility.
  • Limit and track keys/entry cards, paying special attention to those issued to employees who are no longer with the company.

EN ROUTE SECURITY

  • Avoid high population centers, including downtown and/or metropolitan areas, tunnels and bridges, where possible (see 49 CFR 397.67).
  • Ensure that all hazardous materials are delivered expeditiously.
  • Instruct drivers to lock vehicles when in transit or unattended.
  • Reinforce attendance and parking rules in 49 CFR Part 397.
  • Drivers must be aware of vehicles that may be following their truck and strangers asking inappropriate questions.
  • Be suspicious of individuals asking you to stop as a result of an alleged traffic accident. If unsure whether the accident occurred, drive to a police station or to a well-lit, busy location before stopping.
  • Be cautious about stopping to help stranded motorists or at accident scenes. If possible, call the State Police instead.
  • Do not pick up hitchhikers.
  • Do not discuss the nature of the cargo at coffee shops, truck stops, over the CB radio, etc.
  • Drivers must remain aware of their surroundings at all times.
  • Drivers should have a means to maintain communication with the company, such as cell phones, two-way radios, CBs, satellite communication systems, etc.

TECHNICAL INNOVATIONS

  • Make yourself aware of technical innovations that could assist in security, such as cell phones, satellite tracking, and surveillance systems.
  • Look at state-of-the-art locks and seals.
  • Are access control systems appropriate?
  • Consider tamperproof locking features for fifth wheels (so that trailers cannot be stolen).
  • Consider installing electronic engine controls that require a code, in addition to a key, to start a vehicle.
  • Consider theft-prevention devices, steering locks, fuel cutoff switches, electrical cutoff switches, and other high-security ignition devices.

MANAGEMENT PREROGATIVES

  • Include fingerprinting (where permitted by law) and photographs of applicants in the employment process.
  • Be aware of personal identity theft, such as using stolen social security numbers, references, etc.
  • Consider running criminal background checks where permitted by law.
  • Consider implementing security training for employees that includes:
    • Company Security Objectives
    • Specific Security Procedures
    • Employee Responsibility
    • Organizational Security Structure

COMMUNICATIONS

  • Develop a communications network with others in the industry in an effort to share information to determine if there is a pattern of activities that when taken alone are not significant, but when taken as a whole generate concern.
  • Develop a means of communication within the physical plant and the vehicle (cell phones, satellite tracking, radios, etc.). Is the system capable of reaching all key personnel?
  • Security messages should be presented to employees by various means such as newsletters, bulletin boards, etc.

READJUSTMENT BASED UPON CURRENT CONDITIONS

  • Emphasize that terrorist activities tend to occur in groups. Security should be heightened if new attacks begin.
  • Increase security measures while the U.S. is involved in military activities in foreign countries.
  • Increase security measures when the U.S. is at a heightened state of alert.

OTHER

  • Suspicious activities should be reported immediately by dialing 311 or 911, as appropriate.


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