GUIDE TO DEVELOPING AN EFFECTIVE SECURITY PLAN FOR THE
HIGHWAY TRANSPORTATION OF HAZARDOUS MATERIALS
Developed by
Battelle and TotalSecurity.US
for
Federal Motor Carrier Safety Administration U.S.
Department of Transportation Washington, DC 20590
GUIDE TO DEVELOPING AN EFFECTIVE SECURITY PLAN FOR
THE HIGHWAY TRANSPORTATION OF HAZARDOUS MATERIALS
Table of Contents
Executive Summary iii Introduction 1 How to Use This
Document 3 Chapter One: Security Assessment 5 Part
A. Reviewing Your Hazmat Operations 5 Part
B. Identifying Relevant Threats and Vulnerabilities 6 Part
C. Addressing the Transportation of Specific Hazardous Materials 7 Part
D. Addressing Your Specific Operations 8 Part
E. Prioritizing Threats and Vulnerabilities 8 Chapter
Two: Security Plan 11 Part
A. Primary Security Objectives 11 Part
B. Specific Security Measures 12 Part
C. Addressing Varying Threat Levels 14 Part
D. Security Plan Components 15 Part
E. Example 16 Part
F. Corporate vs. Terminal Level Planning 17 Chapter
Three: Security Training 19 Part
A. Security Awareness Training 19 Part
B. In-Depth Security Training 19 Part
C. Recurrent Training and Recordkeeping 20 Chapter
Four: Security Plan Administration 21 Part
A. Distribution and Availability 21 Part
B. Updates and Maintenance 21 Part
C. Verification and Evaluation 22 Part
D. Coordination, Cooperation, and Liaisons 22 Appendix
A: Understanding the Security Threat 23 Appendix
B: Issues to Consider in Your Security Assessment 27 Appendix
C: Sample Security Plan Measures 32 Appendix
D: FMCSA Security Contact Reviews 40 Appendix
E: References 46 Appendix
F: Helpful Industry Web Sites 47
October 9, 2003
Executive Summary
This Guide is a tool that motor carriers transporting hazardous materials can
use in developing a security plan as required by the U.S. Department of
Transportation in their HM-232 rulemaking [1]. It is designed to provide motor
carriers with (a) sufficient background to understand the nature of the threats
against hazardous materials transportation; (b) the means to identify the
vulnerabilities to those threats; and (c) an approach to address the
vulnerabilities.
The first step in developing a security plan is conducting a security
assessment. The Guide establishes a framework for reviewing a company's
hazardous materials operations and identifying relevant threats and
vulnerabilities. The focus is on making the assessment specific with respect to
an individual company facility or each type of hazardous material. The Guide
also offers an approach for prioritizing each of the threats and vulnerabilities
that are identified.
The discussion of the security plan introduces a recommended approach for
determining appropriate security measures for addressing identified threats and
vulnerabilities that help to eliminate unnecessary security-related expenses.
Consideration of varying threat levels (such as those indicated by the Homeland
Security Advisory System) and a method for prioritizing potential security
measures is also discussed.
The Guide covers the required security training (awareness and in-depth) and
security plan administration. Administration includes the distribution,
maintenance, verification, and validation of the full security plan as well as
how to best incorporate the insights and support that are available from
industry partners, local community organizations, and law enforcement
agencies.
Introduction
Hazardous materials in transportation are vulnerable to sabotage or misuse
and in the wrong hands pose a significant security threat. The security of
hazardous materials in transportation poses unique challenges as compared to
security at fixed facilities because of the changing environment surrounding a
moving vehicle. Since hazardous materials are frequently transported in large
quantities, once mobile they are particularly vulnerable to theft, interception,
detonation, or release. When transported in proximity to large population
centers, accidental or intentional acts could have serious consequences.
Due to the terrorist attacks committed on September 11, 2001, and subsequent
threats to the transportation system, the Federal Motor Carrier Safety
Administration (FMCSA) conducted over 30,000 Security Sensitivity Visits (SSVs)
between October 2001 and April 2002. The SSVs consisted of face-to-face meetings
between FMCSA or state investigators and top carrier officials to assess
security vulnerabilities and identify countermeasures that can improve security.
FMCSA then began including SSVs as part of all compliance reviews on hazardous
materials (HM) carriers to encourage a high level of vigilance within the
industry.
Also prompted by the September 11, 2001 terrorist attacks and subsequent
threats related to biological and other types of hazardous materials, the
Department of Transportation's Research and Special Programs Administration
(RSPA) issued new regulations under Docket No. HM-232 intended to enhance the
security of hazardous materials transportation [1]. As discussed in more detail
below, the new regulations impose security plan and security training
requirements on certain hazardous materials shippers and carriers.
The Research and Special Programs Administration, which has regulatory
authority over hazardous materials transportation across all modes, published
the HM-232 final rule on March 25, 2003. The HM-232 regulations require persons
who offer certain types and quantities of hazardous materials (hazmat) for
transportation or transport in commerce to develop and implement security plans
by September 25, 2003. In addition, all hazmat employees, as defined in the
Hazardous Materials Regulations (HMR, 49 CFR Parts 171-180), must receive
training that provides an awareness of security risks associated with hazmat
transportation and methods designed to enhance hazmat transportation security.
Persons who offer for transportation or transport the following hazardous
materials must develop and implement security plans that conform to the HM-232
requirements:
HAZARDOUS MATERIALS SHIPMENTS SUBJECT TO
HM-232 |
Material |
Threshold (if specified) |
Class 7 - Radioactive |
Highway route controlled quantity (HRCQ) |
Division 1.1, 1.2, or 1.3 - Explosive |
More than 25 kg (55 pounds) |
PIH in Hazard Zone A |
More than 1 liter (1.06 quarts) |
HM in a bulk packaging (container) |
Capacity of packaging equal to or greater than: Liquid or gas:
13,248 liters (3,500 gallons) Solid: 13.24 cubic meters (468 cubic
feet) |
HM in a non-bulk packaging |
Total gross weight equal to or greater than 2,268 kg (5,000
pounds) |
Select agent or toxin regulated by the Centers for Disease Control and
Prevention (CDC) |
|
Any HM shipment requiring placarding according to subpart F of the
HMR |
|
Many motor carriers include security measures in their standard operating
policies and procedures. The HM-232 final rule requires a more systematic
approach to transportation security and a specific focus on potential terrorist
or criminal threats. While any plan that meets the specific provisions of the
rule will be acceptable, many organizations will have to make adjustments to
existing plans to cover all required areas. Other organizations will develop
their security plans for the first time in response to this new regulation. The
information in this Guide should serve as a tool in developing a security plan
required by the U.S. Department of Transportation.
You should also be aware that the U.S. Patriot Act, passed in October 2001,
included a provision for requiring background checks for individuals operating
motor vehicles transporting hazardous materials [2]. The Transportation Security
Administration (TSA) enacted regulations on May 5, 2003 implementing this
provision. TSA's rule requires routine background checks for drivers with a
hazmat endorsement on their Commercial Drivers License (CDL). The required
background checks must include a review of criminal, immigration, and FBI
records [3].
How to Use This Document
Although this Guide is directed at motor carriers that transport hazardous
materials, hazmat shippers may also find this publication a useful tool. The
information herein is a tool that you may apply in developing a security plan
required by the U.S. Department of Transportation. While the main chapters guide
you through the steps a motor carrier needs to take and the issues they need to
consider, the appendices provide more in-depth information that will be helpful
in the development of an effective security plan. Following is a review of the
chapters and appendices:
- The Introduction provides a review of the security planning process and of
the background for this Guide. If you would like more information about
terrorists and their operations, refer to Appendix A.
- Chapter One guides you through your security assessment to identify the
threats and vulnerabilities to your operations. A security assessment is a
necessary first step in preparing your security plan. If you would like more
detailed information on issues to consider, refer to Appendix B.
- Chapter Two addresses the detailed components that need to be included in
your security plan and provides examples on how to construct the plan.
Personnel security, unauthorized access, and en route security are
specifically addressed. Additional guidance for companies with operations at
many locations is also included. This chapter does NOT provide a comprehensive
list of security measures for you to implement; rather, it guides you in
determining which ones are right for you. Some examples are included in this
chapter to get you started and more are included in Appendix C.
- Chapter Three discusses the required components of a training program and
how to develop one.
- Chapter Four covers the administration of your security plan including how
it is provided to your employees and maintained. This section also covers
establishing relationships with other entities, such as local law enforcement,
to augment and enhance your security.
- Appendix D outlines the approach that the Federal Motor Carrier Safety
Administration (FMCSA) is taking to ensure that the highway transportation of
hazardous materials is secure and that motor carriers are in regulatory
compliance.
- Appendix E at the end of this Guide contains a list of references and
citations.
Acronyms
CDC |
Centers for Disease Control and Prevention |
CFR |
Code of Federal Regulations |
CDL |
Commercial Drivers License |
DOT |
U.S. Department of Transportation |
DHS |
U.S. Department of Homeland Security |
FMCSA |
Federal Motor Carrier Safety Administration (in DOT) |
FBI |
Federal Bureau of Investigation |
HM-232 |
Security Requirements for Offerors and Transporters of Hazardous
Materials, a rulemaking issued by RSPA |
HM, hazmat |
Hazardous Materials |
HMR |
Hazardous Materials Regulations |
HRCQ |
Highway Route-Controlled Quantity (of RAM) |
HSAS |
Homeland Security Advisory System (with five color-coded levels) |
PIH |
Poisonous by Inhalation (synonymous with Toxic by Inhalation) |
PSO |
Primary Security Objective |
RAM |
Radioactive Material |
RSPA |
Research and Special Programs Administration (in DOT) |
SSV |
Security Sensitivity Visit |
TSA |
Transportation Security Administration (in DHS) |
WMD |
Weapons of Mass Destruction |
Glossary
carrier |
The company transporting a shipment from the shipper to the
consignee |
consignee |
The company (or person) to which a shipment is destined (the
receiver) |
likelihood |
The probability of something happening; for HM security, the
attractiveness of something to a terrorist is used in place of likelihood
|
may |
Indicates an option for consideration only. |
must |
Indicates something which is required for you to do by
regulation |
non-specific but credible |
Refers to a threat that is general in nature but is still believed to
be realistic |
primary security objective |
Term used to represent a main goal in addressing security
vulnerabilities; security measures are chosen to meet the primary
objective |
risk |
Represents the exposure to a hazard; for HM security, risk is the
likelihood of a terrorist act combined with its probable
consequences |
specific and credible |
Refers to a threat that is focused (perhaps to a city, bridge, or
industry) and believed to be realistic |
specific security measure |
A policy, procedure, device, etc. that is put in place to reduce one
or more vulnerabilities that an organization may face |
shipper |
The offeror of the shipment for transportation (the origin) |
should |
Implies a recommendation only - it is not required |
threat |
A source of danger; for HM security, this includes terrorists and
criminals and the types of attacks they might initiate to achieve their
objectives |
vulnerability |
A weakness; susceptibility to attack or injury. |
Chapter One: Security Assessment
One of the most critical components of HM-232 is the assessment of possible
transportation security risks for covered shipments of hazardous materials. Many
companies have implemented numerous security measures without examining the
threats against their operations and their vulnerabilities to those threats.
Threats are sources of danger and can include both criminals and terrorists and
the attacks that they might initiate to achieve their objectives.
Vulnerabilities are weaknesses that make you more susceptible to attack or
injury.
HM-232 requires companies to complete a written security assessment and to
develop a security plan that is based on the assessment. This Guide will assist
motor carriers in conducting their security assessments and in developing their
security plans.
Part A. Reviewing Your Hazmat Operations
When conducting a proper assessment of the threats to and vulnerabilities of
your operation to a terrorist attack or terrorist activity, the types of
information to consider include: (a) the type of hazardous material you
transport, (b) the frequency and quantity of shipments, (c) the packaging type,
and (d) the amount stored on-site. You will also need to identify and address
your business practices (including relationships with external partners), such
as the emergency response information that is available on site, and physical
assets that are a part of your hazmat transportation activities.
A.1 Business Practices
You should analyze your company's business practices that affect the
transportation of the hazardous materials included in HM-232 to identify
potential security vulnerabilities. Such business practices may include:
- Taking and processing orders, including dispatching;
- Hiring and human resources-related activities (which relate to ensuring
the trustworthiness of employees);
- Job descriptions, organization charts, and reporting structures for
responsible management and decision making, security policies, and reporting
(which all relate to who has access to information and who makes key
decisions);
- Facility and building access policies and procedures;
- Qualification and selection of outside service providers (contractors)
with access to hazmat handling areas; and
- Policies and procedures on distributing information related to hazmat
shipments, including to business partners.
A.2 Physical Assets
You should analyze each physical asset (facility, terminal, etc.) used in the
transportation of hazmat to identify potential security vulnerabilities. This
analysis should consider, at a minimum, the following:
- Exterior surveillance and line-of-sight attack potential;
- Areas of concealment;
- Normal and potential vehicle and pedestrian paths;
- How congestion, choke points (where vehicles or pedestrians may get
delayed during an evacuation), and other circumstances might reduce the
effectiveness of your security measures;
- Your immediate surroundings - assess the potential for layered protection
or and the nature of potential nearby threats;
- Storage facilities, transfer, loading, and unloading areas;
- Business offices, storage of empty hazmat packagings; and
- Visitor, vendor, and employee parking.
In addition, you should examine each configuration of transport vehicles for
vulnerabilities based on use and the likely routes. Unlike many facilities,
where the areas that are most in need of protection (such as critical operation
centers) are separated from an outer fence by a considerable distance, there is
no protective buffer surrounding vehicles on the road. Vehicles, therefore, can
be more vulnerable. You should also identify and assess facilities that are
owned and/or operated by others, such as truck stops, and rest/parking
areas.
Part B. Identifying Relevant Threats and Vulnerabilities
It is important to remember that in the case of hazardous materials, the
assumed agenda of terrorists is to convert the material, package, or vehicle
into a weapon; in other words, controlling the material is an operational act in
support of a larger attack plan. This can occur in several ways. The three
principal methods are:
- The material can be purchased and delivered to the target location or an
intermediate site to be transported later.
- The material can be acquired by theft either in transit or at a storage
site. This part of the operation can take the forms of fraud, stealth, or
violence.
- The material can be converted to weapons use directly while under
legitimate control. This could be a violent event that takes the form of a
catastrophic release, typically by explosive or mechanical attack.
Taking the case of the legitimate purchase, there is nothing in the HM-232
security requirements that calls for validation of the consignee. However, it
would be prudent business practice (but not required) to verify that an order of
unusual character, such as a large shipment of toxic-by-inhalation gas to a
stadium, is in fact expected and required. When it comes to determining which
security measures are appropriate for your company, such as checking with
consignees, only you can be the judge.
Material acquired by theft is not unlike criminal activity associated with
high value shipments. Unlike typical criminal profiles, however, the terrorist's
readiness to employ extreme violence is much greater. Where the criminal may be
reluctant to employ deadly force because of the repercussions if captured, the
terrorist may not expect to survive the operation and so eventual capture is
meaningless as a deterrent. Without considering the tactics used, a terrorist's
objective is to take control of the material and transport it to a target
location for use as a weapon. Maintaining control of the cargo, not the vehicle,
is the primary concern here.
In the third case, the material is converted to a weapon on the spot. This
means that the material must be located at or near the final target. Storage
areas and transport routing that are near desirable targets should be areas of
concern. The 'Trojan Horse' scenario, where a device is attached to a shipment
and detonated at the desired moment and location, and the 'Intercept' where a
device is located in anticipation of the material's passage, are the two most
likely options.
What you can derive from all of the preceding discussion is that each method
requires specific knowledge in order to be successful. There are basically three
ways in which a terrorist can obtain this information:
- Conduct research of public records and reference materials, including
company websites, annual reports, and marketing information;
- Observe operations; and
- Acquire knowledge from participants in the company's operations or by
actually taking part themselves (as an "insider").
Public information may be of limited value beyond learning the
characteristics of the material being pursued. Observation is an operational act
that involves exposure and risk of discovery. Direct knowledge through
participation or trust of those in a position to know provides both detail and a
high level of confidence in the information. This is the reason why business
processes are of a security concern to HM-232. For additional insight into
terrorists and their operations, see Appendix A.
Part C. Addressing the Transportation of Specific Hazardous
Materials
Although a major portion of the security plan may be uniform across a
company's entire operation, planning must recognize that different classes of
material may require different strategies. This is due to the nature of the
material and the character of the transportation processes involved. The
following is a discussion of several materials:
- Radioactive materials (RAM) are not likely to be used in creating a
fission or fusion bomb, but as a persistent contaminant, that represents both
a real health hazard and an emotional trigger for widespread panic. The most
publicly discussed tactic is the 'Dirty Bomb', more appropriately referred to
as a 'Radiological Dispersion Device' or RDD. This device uses conventional
explosives to disperse the contamination, potentially creating an acute
situation for large numbers of people. Because certain types of RAM are
effectively invisible and easily spread through contact, less spectacular
methods of dispersal must also be considered.
- Explosives require proximity to the target and sufficient quantity to be
effective. By controlling either of these two parameters, the potential
consequences can be reduced.
- Poisons are similar to RAM in that they represent a dispersal attack in
order to be effective. Unlike RAM, dispersal of poisons must maintain an
effective level of concentration to be successful. This tends to limit use of
these materials to situations where the dispersal can occur within a defined
volume.
- Flammables represent the most common category of hazardous material
shipped and transported. The sheer number of opportunities and the diversity
of locations and circumstances involved make flammable materials cause for
concern.
- Biological materials represent means for dispersal attack, similar to RAM.
CDC-regulated materials represent a potential for the introduction of
infectious disease into the population.
Another category of hazardous materials of interest to HM-232 includes all
other placarded materials. Although these may not present the level of weapons
potential as those discussed above, some of them are capable of significant
economic and social disruption when intentionally released with malicious
intent, while others do not require any additional security measures to be
implemented.
Part D. Addressing Your Specific Operations
Companies have different and distinct types of operations. For example, some
companies act as both shipper and carrier. In addition, some carriers maintain
their over-the-road operations entirely separate (and differently) from their
local pickup and delivery operations. It is appropriate to consider the distinct
character of each of your operations in your security assessment.
HM-232 addresses the transportation of hazardous materials. It does not cover
fixed facility operations unless those operations are incidental to
transportation, such as loading, unloading, and certain temporary storage. At a
shipper facility, the elements that you should examine include the preparation
of hazmat for transportation, selection and use of appropriate packaging,
preparation of shipping documentation, loading operations, and so on. To the
extent that this information can be hidden, the vulnerability can be reduced.
You may want to include issues related to long-term storage of hazmat at your
facilities in your security assessment, but are not required to do so by HM-232.
Both shipper and carrier operations involve the processing of orders. The
'business side of the house' is important because of the storage and shipping
information. There are two groups of people of concern: those that must process
or act on the order information and those who may have access to the information
but do not typically process or act on it. Although each person who processes an
order should be considered a potential threat, they also represent an
opportunity for threat recognition.
Carrier operations present several difficult security issues. Effective
status and tracking of the cargo may be impractical, forcing strategies that
involve the personnel and transportation equipment as surrogate indicators to
potential problems. The variety of situations typically encountered while en
route present many vulnerabilities that a terrorist can exploit.
Part E. Prioritizing Threats and Vulnerabilities
Companies have limited security dollars, making it necessary to prioritize
the vulnerabilities to be addressed and the primary security objectives (PSOs).
There are many ways to do a prioritization, but most rely on some form of
subjective ranking system. For example, you may prioritize the threats you face
as highly likely, somewhat likely, possible, unlikely, or improbable (of course,
you could use a greater or fewer number of categories). You may then rate your
vulnerabilities (perhaps on a scale from very low to high), considering how easy
you believe it would be to exploit that vulnerability given your current
operations. Combining these categories can help you focus your energies and
limited resources on those vulnerabilities most easily exploited that correspond
to the highest threats. You can treat this combination of threats and
vulnerabilities as the relative likelihood of a terrorist act. However, this is
not likelihood in the traditional sense of the word, since there are not
sufficient historical data to know the probabilities of any future terrorist
acts; it is simply a good substitute. This analysis will help you see what
terrorists find attractive. The table below shows one example-assigning a value
from 1 to 4 to each combination of threat and vulnerability, with a value of 4
having the highest likelihood. Let's say you have identified three threats to
which you have some vulnerability. For one of these threats you have a single
vulnerability that could be exploited; however, for the other two, you have two
vulnerabilities each. This makes a total of five threat-vulnerability
combinations. To prioritize these, you would place each of the five combinations
in the appropriate cell in the table below.
"LIKELIHOOD" |
VULNERABILITIES |
THREATS |
Very Low |
Low |
Medium |
High |
Specific and Credible |
2 |
3 |
4 |
4 |
Non-specific but Credible |
2 |
3 |
3 |
4 |
Possible |
1 |
2 |
3 |
3 |
Unlikely |
1 |
2 |
2 |
2 |
Improbable |
1 |
1 |
2 |
2 |
You may also wish to consider the potential consequences of a terrorist act
in each case. For example, you may identify similar threats and vulnerabilities
for operations involving different materials, but the consequences of one
material may be worse than for the others. You could use a ranking scheme
similar to the one used above in which you assign potential consequences to
severe, high, medium, or low categories. Combining consequences with their
"likelihoods" provides you with a measure of risk. Since our "likelihoods" are
only approximations of the true probability of a terrorist event, the risk would
also be a crude approximation of the actual risk. One way of combining
likelihood and consequence to determine risk follows the same approach used
above. Take each of the threat-vulnerability combinations (which represent the
"likelihood") and place them in the appropriate cell in the following table,
depending on how severe the consequences would be if the threat were able to
exploit that particular vulnerability.
"RISK" |
CONSEQUENCES |
LIKELIHOOD |
Low |
Medium |
High |
Severe |
4 |
2 |
3 |
4 |
4 |
3 |
2 |
3 |
3 |
4 |
2 |
1 |
2 |
3 |
3 |
1 |
1 |
1 |
2 |
2 |
Of course, you may chose to assign different values to the cells in these
tables, but you should focus first on the elements in the top right of the
"Risk" table. Anything you place in a cell with a value of 3 or 4, for example,
might warrant further attention. Ultimately, you have to decide which
vulnerabilities you need to address, but this approach provides you with a
method for prioritizing them.
Chapter Two: Security Plan
Your Security Plan should be a complete document and should include: (a)
information on your security assessment; (b) how you address any vulnerabilities
identified in the assessment; (c) what security measures you have adopted; (d)
how, when, and by whom they will be implemented; (e) your organizational
structure; and (f) the responsibilities of the various employee positions. In
essence, your security plan is the detailed map of how you address the security
assessment.
Each motor carrier should evaluate the threats it faces and its
vulnerabilities based on its unique operations and facilities and should
recognize that a cookie-cutter approach is not appropriate. The measures adopted
by your company to address your vulnerabilities do not need to be complex or
expensive to be effective, but the justification and rationale to support them
needs to be sound and documented. The key to developing adequate security
measures is to think "prevention." Understand that the threat is very real and
try to think like a terrorist when assessing your security weaknesses.
A security plan can be formatted using any structure that makes sense for
your company. An example of a good model would be to structure or organize it
into the following components or sections: Personnel Security, Unauthorized
Access, and En Route Security. These areas are specifically required to be
addressed by RSPA's HM-232 rule and must be included in the plan in some
form.
For each component, it is strongly recommended that you provide a complete
description of the relevant specific security measures you will use to reduce
your vulnerabilities. You should also discuss personnel roles and
responsibilities for implementing each measure. Remember, the most effective
security measures do not necessarily involve high-tech or high-cost
implementations. Sometimes very simple changes in procedures can achieve the
same result as a much more costly equipment-based solution.
Model security plans are available from some vendors and representatives of
the hazmat transportation industry that may provide guidance for development of
your plan. However, it should be noted that some plans will be more stringent
than required by HM-232 and others may not adequately cover all areas addressed
by HM-232. Model plans may not address the unique circumstances at each facility
or for different types of trucking operations (e.g. truckload versus pickup and
delivery). You are responsible for ensuring that any model plan you use has been
specifically adapted to your operations. This is particularly true for
organizations that have many sites, facilities, or terminals. A corporate-wide
plan (and the accompanying security assessment) may not be specific enough to
each location to be adopted outright. Additional consideration and modification
will probably be necessary for each location.
Part A. Primary Security Objectives
While many security plans are developed by matching specific security
measures to the vulnerabilities identified in a security assessment, we
recommend taking a step back to think about what you want each security measure
to accomplish. Your security plan should include specific objectives/goals and
measures for your company and its employees. These are your primary
objectives.
For example, you determine that your facility is vulnerable to a terrorist
bringing a weapon into your facility. You already have a fenced facility and
have located visitor parking outside the front gate. Your main goal is to
prevent an armed terrorist from entering through the front gate. Your first
thought may be to set up airport-type screening that includes a metal detector
and an X-ray machine at the front gate. Such devices are very expensive and
require a staff that is well-trained in screening procedures. There are other
things you can do to achieve the same goal at a lesser expense. You could use
guards with magnetic wands to detect weapons that people are carrying and they
could manually inspect bags and briefcases. You may even forgo the wands and
rely only on visual weapons checks. All these approaches can be equally
effective with properly trained employees, yet each is progressively cheaper to
implement.
A real-world example proves the value of this approach. A transit agency on
the West Coast recently completed an extensive security review. It was
recommended that they implement a very costly (millions of dollars) group of
measures to protect their buses while they were in the yard. These included
additional fencing and lighting, intrusion detection systems, extra guards and
patrols, guard dogs, and more. A second review determined that all they wanted
to do (their primary objective) was to prevent a terrorist from planting a bomb
on a bus left overnight in their yard, so that it could be detonated later when
the bus was in service and carrying passengers. They determined that adding a
couple of new items to their existing pre-trip inspection checklist (looking in
the few spaces where a bomb could be hidden that they were not already checking)
would meet that objective. The cost for this procedure was minimal, saving
millions of dollars.
As long as your measures meet the primary objective, you have done your job.
Choosing the specific measure(s) for each primary objective can be based on any
number of factors, including cost and other benefits. In the example above,
there may be other tradeoffs to consider, such as the throughput that each
method will allow. Many more people per hour can be screened through
airport-type security devices than with manual inspection so the former may make
sense for a high-volume facility.
Part B. Specific Security Measures
After you identify the primary security objectives (PSOs) for each component
of your security plan, you need to identify the specific security measures (or
steps) you will implement to achieve each objective. A security measure is a
policy, procedure, device, or system that is put in place to reduce one or more
vulnerabilities that you may face. If one of your PSOs is to prevent access to
hazmat vehicles by non-employees, an appropriate specific security measure might
be to require employee identification cards and have a security officer check
cards in the area where the hazmat vehicles are parked. Another option might be
to park all hazmat vehicles in a secured area and only allow access by employees
with identification cards and a signed dispatch order listing a specific
vehicle.
It is important to remember that specific security measures can be
hardware-based (fences), technology-based (motion detection), policies and
procedures oriented (always ask to see the visitor badge of anyone you do not
recognize), or training-based (to reinforce policies that may not be followed
properly).
The following graphic illustrates how specific security measures are related
to the PSOs within a security plan. A security measure that is used to satisfy
more than one PSO should be listed (by reference) in each instance and
cross-referenced in the event of future changes.
As you identify PSOs and specific security measures (SMs) that are
appropriate for your organization, you can use an approach similar to the one
used to identify "risk" in Chapter One, Part E to select appropriate SMs. You
can determine whether each PSO and the related specific SM you implement will
have a high, medium, low, or very low impact (or another, similar ranking) on
reducing or eliminating specific vulnerabilities. The reduction or elimination
of vulnerabilities is the security benefit of that PSO and its related specific
SM. Those PSOs and specific SMs that allow you to significantly reduce your
vulnerabilities to the highest level of risks are those that have the greatest
benefit. For example, if you are considering one SM that is extremely effective
in addressing a vulnerability to a threat that, when combined with your
vulnerabilities and potential consequences, you have placed at the bottom of
your risk ranking, you would place that SM in the bottom right cell in the table
below (risk=1 and reduction in vulnerabilities=high).
BENEFIT of Security Measures |
REDUCTION IN VULNERABILITIES |
RISK |
Very Low |
Low |
Medium |
High |
4 |
2 |
3 |
4 |
4 |
3 |
2 |
3 |
3 |
4 |
2 |
1 |
2 |
3 |
3 |
1 |
1 |
1 |
2 |
2 |
Ultimately, you need to select those PSOs and specific security measures that
provide the greatest benefit for the least cost. The "Prioritizing PSOs and
Specific SMs" table below can provide you a way to examine the tradeoffs between
cost and benefit for each PSO and its related specific SMs. You would most
likely want to implement the objectives and associated measures with a value of
4 in this table (high benefit and low cost) before you would implement those
with lower numbers. Your assessment of which measures are appropriate for your
organization needs to consider all your vulnerabilities and that more than one
measure that you are considering may address the same primary objective. In that
case, you may only want to implement one of the measures and then focus on
finding the best measure for another vulnerability. Of course, you may choose to
assign different values to the cells in the table, but the general concept is to
focus first on the measures you place in the top right-those with higher benefit
and lower cost.
PRIORITIZING PSOs and SPECIFIC SMs |
IMPLEMENTATION COST |
BENEFIT |
Very High |
High |
Medium |
Low |
4 |
2 |
3 |
4 |
4 |
3 |
2 |
3 |
3 |
4 |
2 |
1 |
2 |
3 |
3 |
1 |
1 |
1 |
1 |
1 |
Part C. Addressing Varying Threat Levels
The U.S. Department of Homeland Security determines the national threat level
based on information it receives from the various security organizations. The
five levels of the Homeland Security Advisory System (HSAS) are color-coded
based on the assessed threat condition. A low condition (green) indicates a low
risk of terrorist attack; a guarded condition (blue) indicates a general risk;
an elevated condition (yellow) indicates a significant risk of terrorist attack;
a high condition (orange) elevates the level to a high risk; and a severe
condition (red) is the highest level, indicating a severe risk of attack and
requires the highest level of security.
The national threat level may be increased by one or more levels depending on
the nature of any pending threats. For example, if an attack occurred under a
guarded threat level (blue), the level would be immediately raised to severe
(red). While it is not required that your plan address varying threat levels, it
is highly recommended. Some organizations adopt a system with less than five
threat levels (for example, often green, blue, and yellow are lumped into a
single category, resulting in three threat levels).
Your security plan should address the specific measures or actions to be
implemented for each of the threat levels. Again, some of these measures may
require only a policy change, while others may require a company to incur
up-front costs at the lowest threat level to prepare for the highest threat
level. You must already have the measures identified and ready to be implemented
if a "red" threat condition is declared. Here is an example of why you need to
think through your measures to see if there may be a problem with
implementation. If your plan includes the use of off-duty police officers for
security to satisfy a primary objective at orange or red threat levels, you may
have a problem. When you need them most (at the red level), they are unavailable
- having been assigned to perform other duties. Increased staffing needs for the
police at the orange threat level may make them unavailable. Therefore, an
alternative strategy or contingency plan would need to be included to address
this deficiency.
When considering how to respond to varying threat levels, you should remember
that the threat to your operation may be elevated for various reasons, including
type of hazmat hauled or location of your facility, even if the national threat
level is not raised. For example, there was a recent alert to possible terrorist
threats in a state located in the Midwest, but HSAS remained at yellow. Motor
carriers operating in that state, however, might have implemented their plans
for the orange level. Future threats and alerts could be specific to your
location, as in this example, or to your industry.
Some examples of general measures to address the varying threat conditions
are provided in the table below [4]. A more specific example is provided at the
end of this chapter.
Threat Condition |
Measures |
LOW |
A low risk of terrorist attacks. |
General measures include ensuring personnel receive proper training on
the HSAS; regularly assess vulnerabilities of all facilities and regulated
sectors. |
GUARDED |
A general risk of terrorist attacks. |
In addition to protective measures for low condition, review and
update emergency procedures; check communications with drivers and
employees. |
ELEVATED |
A significant risk of terrorist attacks. |
In addition to protective measures taken in guarded condition,
increase surveillance of critical locations; implement contingency and
emergency plans, as appropriate. |
HIGH |
A high risk of terrorist attacks. |
In addition to protective measures for elevated condition, driver
should take additional precautions when stopping en route; restrict
facility access to essential personnel. |
SEVERE |
A severe risk of terrorist attacks. |
In addition to protective measures for high condition, monitor or
constrain driver travel or locations for stopping. |
As the table shows, with each increase in threat, additional measures are
implemented. Note that while you may implement additional measures as the threat
level is raised, you must be prepared for such implementation well in advance of
actual implementation. When the threat is elevated, it will be too late to shop
for equipment or to train employees.
Part D. Security Plan Components
As discussed above, there are three major components that must be included in
your security plan in some form: personnel security, unauthorized access, and en
route security. The number and extent of the measures that you choose to
implement for each component is solely dependent on your analysis of your
threats and vulnerabilities and your determination of the cost-effectiveness of
each measure for your organization. A brief description of each component and
security general objectives is provided below. More detailed examples of primary
objectives and security measures for each component are included in Appendix C.
D.1 Personnel Security Component
Personnel security includes confirmation of identity and credentials.
Identification of personnel is the foundation for access control, based on
trust. This means a degree of confidence that an individual is who he represents
himself to be and has the skills and experience claimed. Higher levels of trust
relate to whether the individual can meet various operational safety and
security requirements and even whether they are allowed access to secured areas
or information systems. For example, to confirm the identity and credentials of
job applicants, one security measure that can be used is to check the
applicant's motor-vehicle record-a regulatory requirement for commercial
drivers.
Personal security and safety of your personnel is an essential element of
this component. This begins with the ability of the individual to recognize
threatening situations, but must also be supported by systems and infrastructure
that provide the capability for a proper response. For example, identifying
critical personnel and establishing procedures to protect them are two security
measures that you should consider adopting.
D.2 Unauthorized Access Component
How you control access to your site and to important information needs to be
addressed in your plan. An example of controlling access to your site might be
to install an early-warning system, such as closed-circuit television, to
observe your facility externally and to actively monitor critical spaces.
Another example might be installing physical barriers. Examples of controlling
access to information include requiring passwords, installing a
computer-intrusion-detection system, and monitoring Internet activity in your
organization.
D.3 En Route Security Component
A vehicle in transit represents not just a moving target, but a critical
space under constant exposure to an uncontrolled environment harboring a
diversity of threats. A critical space is an area that is essential to your
operations, such as a dispatch center, hazmat storage area, or an individual
vehicle. When defining primary objectives, it is important to remember that the
cargo is the prime source of consequential damage. Security measures that do not
link directly to the regulated materials in some way, but just the vehicle, may
be of limited value. An example of a security measure for en route security is
regular contact with drivers, whether by telephone or by satellite tracking
systems. Other security measures might be installation of bypass and shut-down
mechanisms or theft-protection devices.
Part E. Example
The following example for a motor carrier with only one small facility will
help illustrate the concepts presented in this chapter. We will provide some
sample security measures, organized by HSAS threat level, for a primary
objective related to personnel security.
Primary Objective: Prevent unauthorized people from entering facility
Sample Security Measures to Implement at Condition Green or Blue
- Implement photo employee ID badge system;
- Establish control and custody process for badges;
- Enforce display of badges for employees and visitors;
- Rely on employees to challenge unbadged individuals;
- Install a fence around facility;
- Install security guard station(s) at gate(s), but leave them unstaffed;
and
- Install perimeter lighting.
Additional Sample Security Measures to Implement at Condition Yellow
- Periodically patrol the site and fence line to spot individuals not
displaying their badges; and
- Occasionally test employee response to unbadged individuals.
Additional Sample Security Measures to Implement at Condition Orange
- Limit site access to one entrance and exit;
- All visitors must be escorted at all times; and
- Post a security guard at the gate.
Additional Sample Security Measures to Implement at Condition Red
- Deny visitors and vendors access to the site.
Notice that a guard gate is used at a higher threat level (orange), but needs
to be installed initially, when the threat is low. Otherwise, it is too late to
start constructing one in the hectic situation that will undoubtedly accompany
an elevated threat. All physical or hardware-based security measures should be
ready to deploy when they are needed.
If you would like to review additional examples of security measures, refer
to Appendix C.
Part F. Corporate vs. Terminal Level Planning
A security plan is not a "one-size-fits-all" plan. Each plan for a site or
terminal will vary based on the facility layout, design, location, highway
access, and operations. In the event your company has more than one terminal,
each terminal would need to have a site-specific security assessment,
considering its unique characteristics. Each terminal would also need a
site-specific security plan developed for and maintained at that facility.
Policies or procedures may be set at the corporate level in some cases, but when
implemented, may need some modification at the terminal level.
Some companies, such as chemical manufacturers, group their facilities
according to the nature of their operations and the types and quantities of
materials that they handle. Security planning may be done at different levels of
detail for each type of facility, with the more critical facilities getting a
very in-depth treatment. Some companies may wish to implement a corporate-wide
security plan for each type of facility since those grouped together are very
similar. This may not be appropriate! Facilities of similar size and material
handling may not have similar threats and vulnerabilities. One may be in a very
rural location and another may be very close to a major urban population,
critical bridge, or other potential terrorist target. Local law enforcement in
one area may be very proactive and effective in deterring terrorist activity and
may be understaffed in another area. Also, consider the routes that hazmat
vehicles take when leaving your terminals. Your facility may not be in a
target-rich environment, but the routes you use may be. Site- and
operation-specific analysis and treatment are always required; however, the plan
you implement may still be the same.
Chapter Three: Security Training
Security training is important to assuring the integrity of the plan,
employee understanding and cooperation, and reducing the company's
vulnerabilities. Security training may be categorized based on the type of
information provided, level of detail, duration of the training, and level of
responsibility of the employee. In addition to hazmat safety training, all
hazmat employees must receive security awareness training and many of them will
also require in-depth security training. Training records for each employee must
be maintained with the security plan and updated as training is completed. The
records must include the employee's name, the most recent training completion
date, a description or copy of training materials, the name and address of the
person providing the training, and certification that the employee has been
trained and tested.
Part A. Security Awareness Training
There is no prescribed format for security awareness training, but it can be
delivered in many forms, including classroom, CD, and over the Internet. RSPA
provides an awareness training module that can be downloaded at no cost from
http://hazmat.dot.gov/hmt_security.htm, or is available on CD at no charge by
calling 1 800 467 4922, ext. 3.
Security awareness training is the most basic form of training and must be
administered to all hazmat employees no later than the date of the first
scheduled recurrent training after March 25, 2003, or by March 24, 2006. Any
hazmat employee hired after March 25, 2003 must receive their security awareness
training within 90 days. The awareness training must address the security risks
involved with hazmat transportation, methods designed to enhance transportation
security, and how to recognize and respond to possible security threats.
Part B. In-Depth Security Training
In-depth security training must be provided to each hazmat employee that is
responsible for implementing or being aware of any part of the security plan by
December 22, 2003. New employees hired after this date must be trained within 90
days. The training should only cover the part of the plan for which the employee
is responsible. It would be poor security practice to train employees in areas
for which they do not have a need to know. Training could be administered by an
instructor in a classroom setting, through the use of computer modules on a CD
with quizzes, or with a training video. Hazmat classification-specific training
with a security component is available through various organizations or Web
sites. Consult with your state or national industry association to identify
resources to assist you in developing or delivering your in-depth security
training.
The training material and content must include instruction or information on
company security objectives, specific security procedures, employee
responsibilities, actions to take in the event of a security breach, and the
organizational security structure. Use of third-party instruction materials may
only augment material that is specific to your security plan. If your security
plan accommodates varying threat levels, your in-depth training should inform
employees of the policies, procedures, and actions expected of them at each
threat level.
Part C. Recurrent Training and Recordkeeping
Currently, the hazardous materials regulations require that all hazmat
employees be given recurrent training every three years on the safe handling,
packaging, and transport of hazmat covered by the regulations. This training
must now include security training. Additionally, the records related to
employees' security training must be kept for the previous three years and for
90 days after termination of employment, as is required for other
training.
Chapter Four: Security Plan Administration
Administration of the security plan requires a commitment from management to
document its operating policies and procedures, complete a threat and
vulnerability assessment, and dedicate time and resources to develop the
security plan and prepare for implementation, if necessary.
Part A. Distribution and Availability
The security plan should be a written document that is secured in a location
accessible to employees with the appropriate company security clearance
(managers, supervisors, security officers) during the normal operating hours of
the facility. The plan should not be openly distributed, but components of the
plan must be available to those employees who are responsible for implementing
it. Due to its sensitive nature, the plan is not a public document and should
never be released to any outside party without a verified and appropriate need
to know.
As with any sensitive information, it is important to develop and rigorously
follow a system of logging and tracking access to the security plan. It is
important to know the name of every individual who has a copy of the entire
security plan and know where it is kept. It may be useful to label each page of
the plan with a "plan clearance level" or similar concept that would indicate
the employee type or company clearance level to which that page applies. This
would help ensure that portions of the plan were not inappropriately distributed
to the wrong employees.
The security plan must be made available to FMCSA investigators conducting
official business as part of security contact reviews or compliance
reviews.
Part B. Updates and Maintenance
Administration also includes monitoring the security plan implementation,
including all components, primary objectives, and specific measures to identify
appropriate changes that should be considered. This activity could involve
employee, vendor, and customer feedback on security measures, review of the
reported security breaches, and periodic testing of security measures for
weaknesses. In addition, communication to and from employees and continuous
improvement to the plan, where warranted, are key elements of plan
administration.
It is very important to review both the security assessment and the security
plan periodically to ensure that both reflect current conditions. For large,
complex companies or operations, it may be appropriate to review the assessment
and the plan every year, while a review every three years may suffice for more
simple operations. The assessment and the plan should be examined when the
threat level changes, particularly if accompanied by specific information on the
nature of the threat.
Any regulatory changes affecting any component of the plan will need to be
considered and incorporated into the plan, if necessary. Of course, any
revisions to the plan must be communicated to affected employees, and all
written copies must be updated simultaneously and consistently. This requires
careful implementation to ensure that no old versions of the plan remain in use.
One possible solution is to require the return of all old copies to a central
location where they are checked off of a master list. It is good practice to
include a version number and date on all pages of the plan.
Part C. Verification and Evaluation
Once you have developed and implemented your security plan, it is crucial
that it is followed completely and consistently. You should establish procedures
for verifying that your employees, contractors, and others are performing their
responsibilities as outlined in your plan. As discussed in Part D below, you may
employ outside parties, such as local law enforcement or industry partners, to
assess your plan and how it is being implemented. You may also wish to test your
plan with mock surveillance, phony job applicants, or other staged events to see
how your plan works under actual conditions.
You should also develop performance measures for your plan to see if it is
making a difference in your vulnerabilities. For example, did the new measures
that you implement reduce theft or property damage? You should develop a
schedule for examining the performance measures you select and assessing your
plan's performance.
These steps will help you identify changes that can make your plan more
effective.
Part D. Coordination, Cooperation, and Liaisons
There can be great benefit from expanding your efforts to include other
partners in your security planning process. Contract carriers may wish to
discuss the security of the hazmat that they transport with their shippers and
consignees, particularly because they will operate within their facilities. It
is important to understand how the security measures that each party implements
will work with, or against, each other.
Your own industry groups are also a good source for new ideas on approaches
to specific security problems and information on best practices. As discussed
earlier, your industry may have developed its own guidance for you to follow.
Just be sure that you are addressing the regulatory requirements as they relate
to your specific operations.
An excellent source for security advice is your local law-enforcement
community, including the local and state police, the FBI, and your state Bureau
of Investigation. These individuals, or consultants with experience in these
organizations, can be a great help in exploring your vulnerabilities as part of
the security assessment. They can be used as third-party auditors to provide an
independent, unbiased review of your final security plan.
Appendix A: Understanding the Security Threat
In the months following September 11, 2001, the media reported several
incidents that provide real-life examples of why carriers and drivers of
hazardous materials must plan and adopt security measures to prevent terrorists
from commandeering their vehicles and loads. A summary of some of the incidents
is provided below to assist you in understanding potential vulnerabilities and
how a terrorist could acquire and use hazmat to inflict casualties or induce
fear and panic. None of the domestic incidents listed have been proven to be
terrorist-related, but they remain suspicious. Hijacking a tractor-trailer
loaded with hazmat that could be used as a weapon of mass destruction (WMD) can
no longer be dismissed. Knowing more about terrorists and their tactics can help
us achieve our goal of preventing terrorist acts from occurring or
succeeding.
- In Mexico, a tractor-trailer loaded with 76 drums of cyanide was hijacked
on May 10, 2002. Six days later, it was recovered along with all but six drums
of the cyanide. The perpetrators were only interested in the truck and not the
hazmat [5].
- Two incidents in March 2003 in the U.S., within two days of each other, in
the same Midwest state illustrate the potential threat posed for drivers of
hazmat CMVs. First, a late-model white GMC Yukon pulled up alongside a fuel
tanker truck and tried to force, at gunpoint, the truck driver to pull over.
The Yukon flashed blue and red lights in its grill and had no license plates.
Two days later a late-model blue Volvo with temporary Delaware tags passed a
tractor-trailer on I-70. The suspicious activity of the car driver and
occupant alerted the truck driver that he might be a potential target for a
hijacking. A few minutes later, another car with temporary Delaware tags and
two similar individuals came alongside and did the same thing. The truck
driver slowed down as he neared his exit and called the state police. The car
passed him and took off.
- On April 14, 2003, the FBI issued an alert in California and Oklahoma
following the theft of a truck transporting 280 propane bottles. There were
other reports of small propane bottles being stolen and one 500 gallon propane
bottle.
- In June 2003, an Ohio truck driver pleaded guilty to two felony charges:
conspiring with al Qaeda to blow up the Brooklyn Bridge and conspiring to
derail a freight train.
- On May 23, 2002, a diesel fuel tanker truck departed Israel's largest fuel
terminal in Haifa, Israel, for a delivery run. Terrorists planted explosives
on the truck while en route, undetected by the driver. When the truck had
returned to the depot and was being reloaded, a remote-controlled detonation
caused an explosion and fire. The fire was barely contained before the
ignition of nearby LNG tanks.
Part A. Terrorist Profiles
In a 1999 retrospective report on terrorism, the FBI classified terrorism as
either domestic or international, depending on the origin, base, and objectives
of the terrorists [6]. There are many types of terrorists. Domestic terrorists
may be delusional individuals (the Unabomber and Timothy McVeigh), extreme
fringe groups (some animal rights and environmental groups), religious cults, or
political resistance fighters (including some so-called "militias").
International terrorists may also include some of these groups, such as the
religious cult Aum Shinrikyo, in addition to groups like al Qaeda [7].
To begin to think like a terrorist and, thus, identify vulnerabilities and
weaknesses in your hazmat operations, you should begin with an understanding of
what motivates an individual or a group to commit a terrorist act. For instance,
al Qaeda is considered a special threat to United States citizens and is a group
that is difficult to fight. It has the resources of a government without any of
the responsibility. It is an umbrella organization with a single point of
contact for multiple militant groups. It has about 700 core members from many
countries and thousands of supporters all over the world. It chooses targets
that are symbolic of its declared enemy, the United States. Its members are
devout followers of Osama bin Laden, not just willing but eager to become the
instrument of delivery in a terrorist act, such as September 11, 2001
demonstrated [7].
Part B. Terrorist Operations
B.1 Operational Acts Needed to Carry Out an Attack
Terrorist organizations, such as al Qaeda, are characterized by meticulous
planning, a focus on inflicting mass casualties, and multiple and simultaneous
suicide attacks. The operatives are highly trained in basic and sophisticated
surveillance techniques. In fact, surveillance is only one step in a sequence of
operational acts that a terrorist must complete to pull off a successful attack.
These steps are the following:
- Targeting-terrorists first must identify a target based on their primary
objectives or motivations. This could include actions designed to inflict huge
casualties or significant economic disruption, attacks on facilities or
buildings with significant iconic value, such as monuments, and/or actions
that will result in high media exposure. Your operation may provide terrorists
the equipment or materials needed to attack their target. If so, then you are
a target, too!
- Casing-this is the careful examination of the terrorists' plan of attack.
They will think through all the steps and what might stop them. They may try
to get copies of your security procedures or plan.
- Surveillance-a close observation of the elements of their plan. They may
watch a facility to determine how many visitors, deliveries, and employees
come and go and how often. Is there a regular pattern, such as during shift
changes?
- Rehearsal-rarely do terrorists carry out an attack without first testing
out their plan. They may stop in front of a truck to see what the driver does.
They may set off your perimeter motion-detection system to test your response
time.
- Attack-looks just like a rehearsal, except it doesn't end the same way.
The goal of a security plan is to develop sufficient security measures to
prevent them from getting to this stage at all!
The following is a list of possible indicators of terrorist casing or
surveillance. The list is not exhaustive, but provides examples of suspicious
activity for which hazmat carriers and their employees should be alert:
- Unusual or prolonged interest in security measures or personnel, entry
points and access controls, or perimeter barriers, such as fences or walls;
- Unusual behavior, such as staring or quickly looking away from personnel
or vehicles entering or leaving designated facilities or parking areas;
- Increase in anonymous telephone or e-mail threats to facilities in
conjunction with suspected surveillance incidents-indicating possible
surveillance of threat reaction procedures;
- Foot surveillance involving two or three individuals working together;
- Mobile surveillance using bicycles, scooters, motorcycles, cars, trucks,
or small aircraft;
- Prolonged static surveillance using operatives disguised as panhandlers,
demonstrators, shoe shiners, food or flower vendors, news agents, or street
sweepers not previously seen in the area;
- Discreet use of still cameras, video recorders or note taking at
non-tourist type locations;
- Use of multiple sets of clothing, identifications, or the use of sketching
materials (paper, pencils, etc.); and
- Questioning of security or facility personnel [8].
B.2 How Terrorists Pick Their Targets
The Department of Homeland Security (DHS) issued an information bulletin
following the terrorist attacks in Riyadh, Saudi Arabia. The May 15, 2003,
information bulletin provides potential indicators of threats involving
Vehicle-Borne Improvised Explosive Devices (VBIEDs) to alert the public of
possible terrorist planning and encourage the reporting of suspicious activity.
The characteristic tactics used in the Riyadh attack were multiple targets,
simultaneous attacks, multiple vehicles per target, and an "assault/breaching
cadre" armed with small arms/weaponry accompanying the VBIED to clear security
personnel and gain access for the suicide bombers.
While most non-bulk hazmat is not easily weaponized, the following classes of
hazmat, when transported in sufficient quantities, are likely to be particularly
attractive to terrorists because of their potential to inflict mass casualties
or significant psychological trauma: explosives (Class 1); radioactive materials
(Class 7); gases or liquids that are poisonous by inhalation (Division 2.3 or
Division 6.1); flammable gases or liquids (Division 2.1 or Class 3); certain
organic peroxides (Division 5.2); certain biological materials (Division 6.2);
and certain flammable solids (Class 4). However, other types of hazmat may also
be terrorist targets because they can be used to manufacture or construct bombs
or other weapons.
The most likely terrorist attack profiles for hazmat transported by
commercial motor vehicle are theft, interception and diversion, and legal
exploitation. For simplicity, diversion is considered a special case of
interception. Theft is the taking of hazmat by means of stealth, deception, or
force. Interception is the instantaneous theft with the cargo released and/or
detonated or ignited while still in the control of the carrier. Diversion is a
special case of interception in which the carrier is directed off its intended
route and to a predetermined target. Legal exploitation would be acquiring
hazmat by commercial transaction or diversion using insiders.
The attack profile used by terrorists will vary depending on such factors as
the type of hazmat transported, type of transportation used, and quantity of
hazmat (truckload, less-than-truckload). The target and attack profile chosen
are based on the attractiveness of a specific profile relative to others, and a
specific material to produce an aggregate impact outcome that maximizes the
following:
- Mass casualties;
- Significant economic damage;
- Extensive psychological trauma; and
- High symbolic value.
The final determination of the attack profile a terrorist would use considers
the following criteria:
- Minimal illegal activity, particularly in the early stages;
- Fewest operational acts;
- Maximizing consequences; and
- High probability of success.
Appendix B: Issues to Consider in Your Security Assessment
This appendix provides additional information that you may consider during
your security assessment process. Not all of the issues, operations, or assets
discussed will apply to your organization, but they may help you ensure that you
have covered all relevant aspects of your operations. It may be beneficial to
conduct your analysis without considering the protective measures that you
already have in place. This will allow you to determine the vulnerabilities you
have that need to be addressed. You can then examine whether your existing
measures are appropriate for eliminating or reducing that vulnerability or
whether less costly alternatives would do the job.
Part A. Facilities
Each physical facility used in the storage, handling, or transportation of
hazmat should be analyzed for potential exploitation by terrorists. As already
mentioned in this Guide, only the activities related to hazmat transportation
should be considered under the requirements of HM-232. The analysis should
consider the following types of facilities.
- Operations large enough to have separate headquarters are likely to use
this office facility as a location for consolidation of order information.
This concentration of data, including security plans, represents an attractive
information-gathering target for a terrorist that is conducting casing
operations (casing is discussed in Appendix A, section B.1).
- Carrier terminals are locations from where trucks are dispatched, fueled,
loaded, or unloaded. Hazmat at less-than-truckload carrier terminals would be
in small quantities and would not stay on site for very long. Dispatch
operations are a potential source of information and can be commandeered in an
effort to redirect shipments along routes to target locations as part of an
attack strategy.
- Some bulk facilities are attended but unsupervised, allowing the driver to
load/unload without further assistance and potentially cursory monitoring.
Some non-bulk operations may present a sufficient level of activity and
potential confusion to cover the diversion of material. Although the presence
of hazmat at bulk carrier terminals may be rare because they often leave the
terminal empty, obtain loads elsewhere, and proceed directly to the consignee,
the equipment used in transport is often stored there. This would not be the
case for private carriers that move their own products.
- Intermodal container shipping represents a set of vulnerabilities and
security opportunities that are unique. The operational goals of speed and
efficiency run counter to awareness and security, placing the security plan at
risk to economic pressure. Although this will be true in all operations, it is
most acutely felt at these intermodal facilities, and you might want to pay
special attention to them.
Part B. Transportation Assets
Each configuration of rolling stock must be examined for vulnerabilities in
light of its intended use and probable routing. Keep in mind that most vehicles
represent a critical space adjacent to an uncontrolled space while they are in
use. In other words, there is no moderately secure buffer zone that surrounds a
truck while en route. This is the most challenging security setting.
For tractors, the issues are relatively straightforward: Who is driving? Is
the person authorized to do so? Are they acting appropriately? Also, sabotaging
the power units may be a concern you must address.
While the hazmat cargo is the primary concern it is usually not possible to
know its status and location directly as this information is most often tied to
the vehicle. You may also want to know whether a cargo tank or trailer has been
separated from the power unit. You should also be concerned about devices and
other contraband placed in or on the equipment to support an attack profile.
Part C. Uncontrolled Support Assets
Transportation beyond local delivery may entail the utilization of facilities
owned and/or operated by others. Those facilities or types of facilities most
often utilized should be an integral part of the security analysis.
Truck stops are an example where the driver will be separated from the
equipment for a significant period. This is mitigated slightly by the presence
of other drivers, the awareness of the truck-stop personnel, and a level of
activity and mutual vigilance that can occur. To the extent possible, route
selection should favor stops that provide some supplemental security in addition
to that provided by the individual carriers. Rest/parking areas cannot be relied
upon to provide additional security or significant opportunities for mutual
support that might be enjoyed at certain truck stops. They are also generally
located in remote areas far from a location where suspicious activity or actual
terrorist operations could be reported.
The use of safe stopping places provides what amounts to a temporary escape
from en route threats and vulnerabilities, trading these in for more predictable
threats and vulnerabilities applicable to any facility. The use of a safe
stopping place must, therefore, result in a net reduction in
vulnerability/consequence, or the en route situation should probably continue.
Hazardous waste is hazardous material without significant economic value.
Certain wastes may still possess weapons potential and should be treated as
appropriate for their classification. The EPA allows transporters of hazardous
waste to store manifested shipments at a transfer facility for ten days or less
without being subject to their storage regulations [40 CFR 263.12]. If you use
these facilities incidental to transportation, you should consider them in your
assessment process.
Part D. En Route Components
Routing may present a variety of security challenges, particularly where
alternate approaches or passages are not feasible or available. To the extent
that routes can be identified, they should be analyzed for threats,
vulnerabilities, and potential consequences (target value). You should also
consider the existing FMCSA regulations on the routing of hazardous materials in
your assessment of en route vulnerabilities [49 CFR 397]. These requirements
include the following:
- Following state and Indian tribe routing requirements;
- Providing drivers of certain explosives with written route plans;
- Ising preferred routes for highway-route controlled radioactive materials;
- Expeditiously delivering hazmat shipments; and
- Other requirements on parking and leaving vehicles unattended.
Where no other specific routing requirements apply to a shipment, FMCSA
requires motor carriers to use routes that do not go through or near heavily
populated areas, places where crowds are assembled, tunnels, narrow streets, or
alleys, with some limited exceptions [49 CFR 397.67(b)].
Explosives, poisons, and flammables all represent significant potential
consequences for weapons conversion in a tunnel scenario. Besides their target
value, tunnels may also be used to facilitate a theft in a controlled
environment.
Long-span bridges, such as suspension bridges, are targets for both their
iconic and economic value. The investment in their construction is justified by
the commercial and social benefits they provide and are often sources of great
pride to the communities that surround and use them. Explosives and incendiaries
would be the most likely tools of attack.
Vehicle ferries may present themselves as a target where a large number of
passengers are involved, and they can be considered an opportunity to commandeer
the vehicle in a controlled situation.
Gaining control of a vehicle against the will of the driver must be
accomplished while the vehicle is either stopped or moving slowly. This is cause
for including steep grades or switchbacks as a consideration. Downhill grades
may also present a vehicle sabotage opportunity where a potential target lies
below the route.
Referencing the discussion in Appendix A, part B.2, sporting and convention
venues, which present opportunities as densely populated targets; government
offices; and many other features near potential routes need to be considered in
your assessment. From a route-selection standpoint, alternatives avoiding these
potential targets should be developed to accommodate the potential for an attack
occurring where the preferred route is unavailable.
Despite the best route planning, not all contingencies can be foreseen. These
can be as ordinary as changes in dispatch orders due to customer direction,
police and/or emergency activity necessitating route closure and detour, or
unannounced construction. How the response to these situations is analyzed is
important because the detour offered may be a diversion operation to place the
cargo near a target or an opportunity to commandeer the vehicle. You must also
consider the routing requirements of 49 CFR 397 and any pertinent routing
requirements of the states or Indian tribes' jurisdictions through which you
travel. These requirements prohibit travel through or near heavily populated
areas, places where crowds are assembled, tunnels, narrow streets, or alleys.
Class 7 radioactive materials have even more stringent routing requirements.
Part E. Personnel
Personnel can be exploited for their information and for their
responsibilities. They can provide unwitting support or be active participants
in an attack operation. They can be developed as assets over months or years or
become victims of sudden violence. Personnel are also the single most valuable
asset in securing the operation. Technology cannot substitute for continued
awareness, informed rational judgment, and responsible actions. You should
address employees, contractors, vendors, and customers in your security
assessment.
Businesses often underestimate the amount of information that employees
possess about day-to-day operations and even strategic decision-making. Casual
conversations eliciting anecdotal situations, particularly with those who have
long histories with the company, can often reveal information vital to operation
planning. Employees should be aware that keeping business confidence is a matter
of security with consequences beyond those of a competitive nature.
Employees in otherwise good standing can also undergo life-changing events
that can manifest themselves in destructive and violent behavior. Coworkers
should be sensitized to indicators that someone may be vulnerable to being
influenced or prone to taking violent action. Employee status changes may be
used as an opportunity and cause for examining factors and researching
information that can reveal potential problems.
Contractors are controlled by the language of the contract. There is a direct
relationship between this language and the cost incurred; the more extensive the
requirements of the contract, the greater the cost. The economic pressure must
be balanced against the need to maintain your planned level of security. From a
security perspective, contractors placed in positions where they can directly
influence operations, or be exposed to security sensitive information, should
have at least the same verifiable character as an employee placed in the same
position and preferably more. In addition, contractors and subcontractors who
handle hazmat that is subject to security plan requirements should be trained as
to their responsibilities under the plan. For example, if a motor carrier
contracts with owner-operators to perform hazmat transportation, the carrier is
responsible for ensuring that each owner-operator complies with the security
plan requirements applicable to their transportation of the hazmat and that the
owner-operator is trained. Owner-operators, which are contract operators,
provide their own transportation equipment, but the carrier that retains them
maintains certain responsibilities. Similarly, contract drivers who use company
equipment also need to be trained to adhere to a carrier's security plan.
Vendors should be provided with the information needed to obtain the best
price and service and nothing more. It is in the vendor's interest to obtain
information about the business for marketing and strategic pricing purposes, but
this does not necessarily provide the shipper/carrier with any benefit. Security
sensitive information should be closely held and shared with vendors only when
sufficient guarantees of confidence have been obtained and there is a strong
business need, such as in the formation of a long-term partnership between
shippers and carriers.
Customers can be unwitting accomplices to an attack operation. Although good
customer service is usually not associated with suspicion, it is appropriate to
share your security concerns with your customers. Where customers refuse to act
in support of security needs, or create situations of increased vulnerability, a
cost/benefit analysis of the relationship may be in order.
Part F. Information Systems
Electronic data is a great benefit as it allows the rapid transfer of
important information to decision-makers. This efficiency can also be exploited.
Information security must include voice and print as well as electronic data.
Security planning and policy may include the following classifications for
information:
- Security sensitive-such as security plans and hazardous materials orders;
- Personnel private-such as health and financial information;
- Business confidential-need-to-know business statistics and strategies;
- Commercial transaction-business-to-business that is not security
sensitive;
- Workgroup shared-internally shared information; and
- Public-freely available to all.
Some organizations contract out their business systems operations, and if you
do, you should consider how this affects your vulnerabilities. Does the outside
firm provide sufficient security measures to prevent your information from being
inadvertently released to others? What employee screening do they have in
place?
Documenting order-processing procedures, including dispatch and other
communication, will define the personnel who are covered by security
requirements due to business processes. This will also reveal those who have
access to information without any responsibility for it. Creating or modifying
processes that minimize information exposure may be indicated-remember, this
includes voice and print as well as electronic information.
There are two elements of internal computer information security, which would
cover your personal computers, servers, local area networks, and intranets. The
first is having physical access to the system; the second is having the ability
to access the system to retrieve or view the information. Telephone modems are
inexpensive, easily attached to a computer, and rarely accompanied by protective
firewall software. These present a potential avenue for putting malicious
software into the system. E-mail and chat programs are a primary source of
business communications and the most likely path that security sensitive
information would take to exit the company electronically.
Many operations maintain public and private access to information over the
Internet. This provides a low-cost and immediate source of information for
customers and employees. The security policy should determine what content is
made available. If an outside service is used to host the Web site(s), the
opportunity for gaining access to unauthorized information via this offering is
nearly eliminated.
Appendix C: Sample Security Plan Measures
Chapter two discusses the recommended use of primary objectives to organize
and select the appropriate security measures for your organization, how to vary
their implementation as the security threat changes, and how to apply them to
varying organizational structures. This section offers more examples on how to
structure the primary objectives and select specific security measures that meet
them. Again, these are offered only as limited examples and may not be
appropriate or sufficient for your organization. You should develop the details
of your security plan to address the vulnerabilities that you have identified in
your security assessment.
Part A. Personnel Security
Personnel security includes confirmation of identity and credentials.
Identification of personnel is the foundation for trust-based access control.
This means a degree of confidence that an individual is who he represents
himself to be and has the skills and experience claimed. This trust progresses
through the ability to confirm compliance with various operational safety and
security requirements to sophisticated permission systems in support of
information and physical access control. Please review the graduated example
below.
Primary Objective: Confirm the identity and credentials of applicants and
employees
Sample Security Measures to Implement at Condition Green
- Check motor-vehicle records;
- Have a criminal background check;
- Confirm past employment;
- Confirm Social Security number; and
- Subject to drug and alcohol testing-drug or excessive alcohol use may make
the individual more susceptible to blackmail or coercion.
the applicant is applying for a driver position and will be transporting
hazardous materials, additional measures should be considered that are more
stringent. These measures include the requirements above and also include the
following:
- Have a CDL with a current hazmat endorsement; and
- Verify citizenship.
Additional Sample Security Measures to Implement at Condition Blue
- All Hazmat employees are subject to a random check of their background and
updating of their personnel files.
Additional Sample Security Measures to Implement at Condition Yellow
- All employees are subject to background checks and confirmation of the
information in their personnel file; and
- Applicants are asked to provide two additional references: one personal
reference and an additional reference for a former employer.
Additional Sample Security Measures to Implement at Condition Orange
- Review the personnel files of employees who were recently terminated by
your company to determine if they may pose a current security threat;
- All employees must use a current credential to access workplaces (no
piggybacking through access-controlled areas); and
- Interview applicants only at certain times and dates.
PERSONNEL PROTECTION
Personal physical security as well as safety is an essential component of
this planning (although not covered by HM-232). This begins with the ability of
the individual to recognize threatening situations. This must also be supported
by systems and infrastructure that provide the capability for a proper response.
Robust communications, particularly the ability to communicate as well as
function under duress, are an essential consideration. Review the graduated
example below. Are there other security measures you would add under a
particular condition?
Primary Objective: Protect personnel deemed as critical
Sample Security Measures to Implement at Condition Green
- Determine if the organization has personnel deemed as critical;
- Establish procedures for the protection of personnel deemed critical;
- Identify and assess potential safe havens within buildings to use in
emergencies (safe havens are areas that are more survivable than other areas
in buildings-basements, hallways, inner rooms, or stairwells-and that
generally offer a significant barrier to an intruder);
- Inform employees about buildings that contain safe havens;
- Have an emergency evacuation plan;
- Ensure the emergency evacuation plan has escape routes, emergency
lighting, and exits; and
- Establish emergency lockdown/shelter-in-place procedures.
Additional Sample Security Measures to Implement at Condition Blue
- Rehearse procedures for the protection of personnel deemed critical;
- Conduct drills moving employees to designated safe havens; and
- Periodically run drills to test the emergency evacuation plan.
Additional Sample Security Measures to Implement at Condition
Yellow
- Ensure that personnel are alerted and familiar with the emergency
evacuation plan, and
- Ensure that personnel are familiar with emergency
lockdown/shelter-in-place procedures.
Additional Sample Security Measures to Implement at Condition
Orange
- Be prepared and implement the emergency evacuation plan or
lockdown/shelter-in-place plans, if required.
Additional Sample Security Measures to Implement at Condition Red
- Implement protection procedures for critical personnel; and
- Implement the safe-haven plan.
Part B. Unauthorized Access
Access control is usually associated with either information or an enclosed
space. In either case, the basic organization and approach to defining the
control strategy should be as follows:
EXTERNAL SURVEILLANCE
Primary Objective: Provide awareness of the area outside the protected space,
so that early warning of possible unauthorized access is provided
Review the security measures below. What others can you think of?
- Install closed-circuit television (CCTV) to observe your facility
externally and actively monitor its view of critical spaces;
- Increase perimeter lighting;
- Have security/law enforcement periodically check identified covered
observation posts that can observe the site;
- Have security/law enforcement periodically check identified
cover/concealment opportunities for criminals or terrorists around the site;
and
- Have security/law enforcement periodically check located
infiltration/egress routes for criminal or terrorist use around the site.
OBSTACLES AND BARRIERS
Obstacles and barriers provide the ability to prevent, discourage, or delay
entry into the protected space at its outer boundaries. Another graduated
example is provided below. Is this approach starting to make sense?
Primary Objective: Maintain a physical safety system
Sample Security Measures to Implement at Condition Green
- Install a fence around the site;
- Fenced sites should have a "clear zone" inside and outside the fence for
unobstructed observation;
- Fenced-in sites should have the capability to have locked, secure gates;
- Install a security alarm system;
- Have sufficient lighting in and around the site; and
- Purchase all necessary equipment for implementation at higher threat
levels. A determination will have to be made as to when to install any
equipment or devices, even if not used until later. If installation is time
consuming, waiting until condition orange or red may be too late.
Additional Sample Security Measures to Implement at Condition Blue
- Periodically check lighting in and around the site;
- Test the security alarm systems;
- Test the site alarm system with local law enforcement; and
- Locking hardware for gates should be case-hardened chain and high-security
padlocks.
Additional Sample Security Measures to Implement at Condition
Yellow
- Routinely check lighting in and around the site; and
- Rehearse actions required if the security alarm system is activated.
Additional Sample Security Measures to Implement at Condition
Orange
- Activate previously installed lighting in areas not routinely covered;
- Activate the emergency law enforcement notification system; and
- Back-up automated access systems with employees.
Additional Sample Security Measures to Implement at Condition Red
- Employ additional portable lighting in and around the site for critical
assets, and
- Employ obstacles or barriers in addition to standard fencing. Examples
would be using concertina or razor wire to provide a double fence, or placing
Jersey barriers to restrict vehicular traffic. While the concertina wire or
Jersey barriers would have to already be on site, they can be put in place
very quickly.
ACCESS CONTROL
Portals should allow authorized personnel, equipment and material to pass
through, and exclude the passage of all else. To accomplish this filtration, it
is necessary to identify those who have entrance permission. Possession, such as
the use of a key, is the most passive form of confirmation, progressing to
biometric and confirmation of access systems that can be real-time updated.
Primary Objective: Maintain control of everyone entering the
facility
Sample Security Measures
What other measures would be appropriate for your operations?
- Determine if employee identification badges are required;
- Establish a control and custody process for the identification badge
program;
- Enforce display of badge for employees while at work;
- Require photo identification badges;
- Limit site access to one entrance and exit;
- Post security guard at gate(s) if not routinely done; and
- Deny visitors, vendors, and job applicants access to the site.
INTRUSION DETECTION
The protected space should not rely totally on boundaries and access
controls. Confidence in the protected space can be maintained by an awareness of
activities, comparing this awareness with established norms to recognize
aberrant conditions.
Primary Objective: Detect unauthorized entry into the facility
Sample Security Measures
Once again, can you come up with other measures?
- Train employees to recognize unauthorized people inside the facility;
- Institute periodic roving patrols of the facility perimeter;
- Install a property alarm system;
- Integrate alarm systems with security force and regularly exercise and
check for reliability;
- Tie site alarm system into local law-enforcement department;
- Have a video camera monitor areas not under direct observation;
- Employ explosive detection devices; and
- Use metal detectors/x-ray machines to screen personnel, visitors, and
bags.
COMMUNICATION AND REPORTING
Fire alarms, intercoms, dedicated communication stations, and similar assets
can be employed in support of detection and response protocols. These
capabilities can be employed in non-traditional ways to augment security
requirements. Graduated examples are listed below. Review these and, as before,
see if you can develop other primary objectives and security measures that would
apply.
Primary Objective: Maintain positive communication with driver
Sample Security Measures to Implement at Condition Green
- Implement a predetermined communication plan with drivers and dispatch;
- Driver and dispatcher communicate as needed via cell phone or radio; and
- Purchase equipment and plan for primary, secondary, or tertiary means of
communication. As mentioned previously, a determination will have to be made
as to when to install any equipment or devices, even if not used until later.
Additional Sample Security Measures to Implement at Condition Blue
- Driver and dispatch maintain regular daily communication via cell phone or
radio; and
- Train with new equipment and test your plan for primary, secondary, or
tertiary means of communication.
Additional Sample Security Measures to Implement at Condition
Yellow
- Implement plan for primary and secondary means of communications,
- Driver and dispatch maintain communication every eight hours via cell
phone or radio;
- Ensure dispatchers are familiar with drivers and their voices, and vice
versa; and
- Employ radio and Internet deceptive measures for routes, times, and
deliveries.
Additional Sample Security Measures to Implement at Condition
Orange
- Employ tertiary means of communications to augment primary and secondary
means; and
- Driver and dispatch maintain communication every four hours via cell phone
or radio.
Additional Sample Security Measures to Implement at Condition Red
- Driver and dispatch maintain communication every two hours via cell phone
or radio; and
- Increase frequency of GPS satellite location messages, if used, for
certain high-hazard materials.
DISPATCH AND RESPONSE
The response capability should be described in terms of timing, capability,
and quantity. Any response that can disrupt or otherwise degrade a potential
attack scenario, without placing additional people at risk or otherwise raising
the potential target value, may be considered as a security measure. Can you
think of other security measures besides those listed below? What could be some
primary objectives that the security measures would address?
Sample Security Measures
- Establish procedures for retaining essential employees on site;
- Have an emergency notification plan for employees (e.g., calling tree);
- Plan for emergency closure, including procedures;
- When a shipment is delayed, late, or does not arrive as scheduled, have an
emergency procedure in place for notification;
- Conduct drills and rehearsals with the security response force; and
- Implement predetermined alternate routes and safe stopping places as
necessary.
INFORMATION SYSTEMS
The use of systems can enhance security and allows for the rapid
dissemination of information. However, these systems must be secure or protected
to prevent intrusion. Once again, some security measures are listed below.
Develop one or more primary objectives and then use the measures below, or
others you think of, to satisfy each primary objective.
Sample Security Measures
- Initiate a mass notification system for emergencies (public-address
system, intercom, alarm);
- Install a computer-intrusion-detection system;
- Monitor Internet activity in your organization;
- Periodically test back-up power for communication systems; and
- Do not pass hazmat shipment data over an unsecured Internet connection.
Part C. En Route Security
A vehicle in transit represents not just a moving target, but a critical
space in constant exposure to an uncontrolled environment harboring a diversity
of threats. When defining primary objectives, it is important to remember that
the cargo is the prime source of consequential damage. Security measures that do
not, in some way, link directly to the covered materials, but just the vehicle,
may be of limited value.
TRACKING SYSTEMS
Satellite systems and other technologies are excellent examples of graduated
security capabilities. The frequency of location and status checks can be varied
with HSAS alert levels and tailored to specific materials, reflecting the threat
environment and potential consequences. A graduated example of measures is
listed below. As you review it, think of what other technology is available to
enhance security.
Primary Objective: Employ technology to enhance en route security
Sample Security Measures to Implement at Condition Green
- Plan for primary (phone/cell phone), secondary (radio), and tertiary
(satellite tracking) means of communications;
- Install by-pass and shutdown mechanisms;
- Install panic-button option in vehicles;
- Install theft-protection devices to disable fuel, hydraulics, and/or
electrical systems;
- Seal tank trailers;
- Driver should always have a communication device readily available to him,
and
- Purchase all other necessary technology devices to be installed.
Additional Sample Security Measures to Implement at Condition Blue
- Train with new equipment and test plan for primary, secondary, and
tertiary means of communications;
- Routinely use primary means of communications; and
- Use high-quality hitch and trailer pin locks.
Additional Sample Security Measures to Implement at Condition
Yellow
- Periodically use secondary means of communication.
Additional Sample Security Measures to Implement at Condition
Orange
- Periodically use tertiary means of communication.
CARGO STATUS AND SEALS
A security plan should include measures to minimize the possibility of theft
of material from a transport vehicle. Cargo seals, tamper-proof locks, and other
technology may be utilized. Some cargo seals are designed to show signs of
physical tampering, while others are electronic and can provide wireless
notification if breached by an unauthorized individual. Note, however, that a
simple locking system may be all that is necessary to deter theft. Of course,
seals are not appropriate in all circumstances. For example, it would be
counterproductive to use seals for bulk petroleum shipments with multiple drops
(unloading).
Sample Security Measures (Can you provide more examples?)
- Check paperwork to ensure it is complete and accurate;
- Inspect cargo manifest and match with cargo;
- See that all tractor/trailer access panels/doors are locked and seals
remain intact/undamaged;
- Implement a search plan for tractors and trailers on the site;
- Routinely check truck transits to ensure routing plan is on file prior to
departure; and
- Arrange with consignee to notify shipper and carrier if the cargo does not
reach its destination.
Appendix D: FMCSA Security Contact Reviews
Due to the terrorist attacks committed on September 11, 2001, and subsequent
threats to the transportation system, FMCSA conducted more than 30,000 security
sensitivity visits (SSVs) between October 2001 and April 2002. SSVs are
face-to-face meetings between FMCSA or state investigators and top carrier
officials to assess security vulnerabilities and countermeasures that can
improve security. FMCSA then began including SSVs as part of all compliance
reviews of hazardous-materials (HM) carriers to maintain a high level of
vigilance within the industry. To complement these efforts, FMCSA has initiated
a new security program called a security contact review (SCR).
A security contact review is a stand-alone visit to a transportation entity
that will evaluate that company's security posture. The goal is to provide
assistance and recommendations for security improvements. Security contact
reviews will initially be conducted at motor carriers that transport the
following high-risk hazardous materials:
- Division 1.1, 1.2, 1.3, in quantities over 55 lbs. and 1.5 explosives in
quantities over 1,000 lbs.;
- Division 2.3 poisonous gases in bulk packages as defined in 49 CFR 171.8;
- Class 7 highway route-controlled quantities of radioactive materials; or
- Division 6.1, packing group I materials and Division 2.1 materials in
cargo tanks with a capacity exceeding 3,500 gallons.
SCRs will be ranked to focus on those carriers that transport these high-risk
materials frequently and in large quantities, or who do not already have
advanced security programs. For example, due to the security programs of the
Department of Defense and the Department of Energy, an SCR is not necessary for
carriers transporting one or more of the above materials under contract to one
of these agencies. Also, a carrier that is listed as transporting Division 1.1
explosives may not transport them in quantities exceeding 55 lbs. Therefore this
carrier would not warrant a SCR.
If a compliance review or safety audit is conducted on an HM carrier
transporting materials warranting an SCR, an SCR should be conducted in
conjunction with the review or audit.
The FMCSA investigators conducting the SCRs will complete a security contact
review checklist, included at the end of this chapter. The investigator will
note any regulatory violations and recommendations for enhancing security and
provide them to the motor carrier.
Please note that the SCR checklist is marked as security sensitive
information (SSI). This refers to a completed SCR and not the blank form. A
completed SCR left with you by an investigator should be treated as you would
your security plan. It should not be seen or distributed to people outside your
company, or to your employees, without a valid need to know and the appropriate
company security clearance.
Federal Motor Carrier Safety Administration US Department of
Transportation
Security Contact Review
Company name:
Address:
USDOT Number:
Date SRC Initiated:
at about:
Select Division:
Conducted by:
Instructions:
- Treat this document as Sensitive Security Information (SSI) [Need to know
basis]. For SSI guidelines, see Volume II, Chapter 4, paragraph 1,
subparagraph d of the FOTM for compliance procedures for handling security
information.
- All No responses require explanation in the comment section.
- If a question involves several parts, only check "Yes" if ALL conditions
are met otherwise, check "No" and discuss in the comment section.
- Use the company's USDOT number as the filename for this document (example:
"OOOOOOO.xls");
- Append additional characters if necessary to avoid overwriting older SCRs
for the same company.
Applicability
- Does the organization fall under the provisions of 49 CFR 172.800
requiring the development and implementation of security plans?
Yes No
Comments:
Security Assessment
- Has a specific assessment of possible transportation security risks for HM
shipments been performed IAW 49 CFR 172.802(a)? Yes
No
Comments:
- Does this Security Assessment adequately capture the specific threats and
vulnerabilities faced by this organization IAW 49 CFR 172.802(a)?
Yes No
Comments:
- Does the Security Assessment adequately capture the specific threats and
vulnerabilities of personnel security IAW 49 CFR 172.802(a)(1)?
Yes No
Comments:
- Does the Security Assessment adequately capture the specific threats and
vulnerabilities of unauthorized access IAW 49 CFR 172.802(a)(2)?
Yes No
Comments:
- Does the Security Assessment adequately capture the specific threats and
vulnerabilities of en route security IAW 49 CFR 172.802(a)(3)?
Yes No
Comments:
- Does the organization periodically assess its security posture IAW 49 CFR
172.802?
Comments:
Security Plan
- Does the Security Plan correlate to the Security Assessment in question 2
above IAW 49 CFR 172.802(a)? Yes No
Comments:
- Is the Security Plan "specific" to the organization IAW 49 CFR 172.802>
Comments:
- Is there a written procedure on actions to take in the event of a security
breach(see 49 CFR 172.704(a)(5))? Yes No
Comments:
- Does the organization have an Oil Spill Prevention and Response Plan IAW
49 CFR Part 130? Yes No
Comments:
Personnel Security
- Does the Security Plan contain a section addressing personnel security IAW
49 CFR 172.802(a)(1)? Yes No
Comments:
- Is the Security Plan's approach to personnel security operation specific
IAW 49 CFR 172.802(a)? Yes No
Comments:
- Are the Security Plan's personnel security measures appropriate for the
security assessment as written IAW 49 CFR 172.802(a)?
Yes No
Comments:
- Are the Security Plan's personnel security measures adequate IAW 49 CFR
172.802(a) even if the security assessment did not identify all
risks? Yes No
Comments:
- Are the Security Plan's personnel security measures security assessment
did not identify all risks? Yes No
Comments:
- Do all drivers required by 49 CFR 383.23(a) to have valid CDLs with
required endorsements have them? Yes No
Comments:
- Does the organization conduct required background checks on drivers IAW 49
CFR 391.23? Yes No
Comments:
- Does the organiation tke measures to confirm information provided by job
applicants hired for positions that involve access to and handling of the HM
covered by the Security Plan IAW 49 CFR 172.802(a)(1)?
Yes No
Comments:
Unauthorized Access
- Does the Security Plan contain a section addressing unauthorized access
IAW 49 CFR 172.802(a)(2)? Yes No
Comments:
- Is the Security Plan's approach to unauthorized access operation specific
IAW 49 CFR 172.802(a)? Yes No
Comments:
- Are the Security Plan's unauthorized access measures appropriate for the
security assessment as written IAW 49 CFR 172.802(a)?
Yes No
Comments:
- Are the Security Plan's unauthorized access measures adequate IAW 49 CFR
172.802(a) even if the security assessment did not identify all
risks? Yes No
Comments:
- Are the Security Plan's unauthorized access measures being followed IAW 49
CFR 172.800(b)? Yes No
Comments:
En Route Security
- Does the Security Plan contain a section addressing en route security IAW
49 CFR 172.802(a)(3)? Yes No
Comments:
- Is the Security Plan's approach to en route security operation specific
IAW 49 CFR 172.802(a)? Yes No
Comments:
- Are the Security Plan's en route security measures appropriate for the
security assessment as written IAW 49 CFR 172.802(a)?
Yes No
Comments:
- Are the Security Plan's en route security measures adequate IAW 49 CFR
172.802(a) even if the security assessment did not identify all
risks? Yes No
Comments:
- Are the Security Plan's en route security measures being followed IAW 49
CFR 172.800(b)? Yes No
Comments:
Security Plan Administration
- Is the Security Plan written IAW 49 CFR 172.802(b)?
Yes No
Comments:
- Is the Security Plan retained IAW 49 CFR 172.802(b)?
Yes No
Comments:
- Are copies of the Security Plan(or relevant portions of it) available to
employees who are responsible for implementing it IAW 49 CFR
172.802(b)? Yes No
Comments:
- Are all copies of the Security Plan updated and revised as necessary to
reflect changing circumstances IAW 49 CFR 172.802(b)?
Yes No
Comments:
Security Training
- Does the training program contain Security Awareness Training IAW 49 CFR
172.704(a)(4)? Yes No
Comments:
- Has Security Awareness training been provided to all hazmat employees no
later than the date of the first schedule training after March 25, 2003 or by
March 24, 2006 IAW 49 CFR 172.704(a)(4)? Yes No
Comments:
- Does the Training material contain In-Depth Security Training IAW 49 CFR
172.704(a)(5)? Yes No
Comments:
- Has In-Depth Security Training been provided to all hazmat employees with
responsibility for implementing the Security Plan by December 22, 2003 IAW 49
CFR 172.704(a)(5)? Yes No
- Does the In-Depth Security Training Material contain company security
objectives IAW 49 CFR 172.704(a)(5)?
Comments:
- Does the In-Depth Security Training material contain organization-specific
security Plan for personnel security IAW 49 CFR 172.704(a)(5)?
Yes No
Comments:
- Does the In-Depth Security Training Material contain organization-specific
security procedures derived from the Security plan for unauthorized access IAW
49 CFR 172.704(a)(5)? Yes No
Comments:
- Does the In-Depth Security Training Material contain organization-specific
security procedures derived from the Security Plan for en route security IAW
49 CFR 172.704(a)(5)? Yes No
Comments:
- Does the In-Depth Security Training Material contain employee
responsibilities IAW 49 CFR 172.704(a)(5)? Yes No
Comments:
- Does the In-Depth Security Training Material contain actions to take in
the event of a security breach IAW 49 CFR 172.704(a)(5)?
Yes No
Comments:
- Does the In-Depth Security Training Material contain the organizational
security structure IAW 49 CFR 172.704(a)(5)? Yes No
Comments:
- Is the Security Training Program correctly administered IAW 49 CFR
172.704(c) and (d)? Yes No
Comments:
Acknowledgement Name:
Title:
Signature: _______________________________________________
Date: ________________________
Appendix E: References
- Research and Special Programs Administration, Docket No. HM-232, 68 FR
14510, available at http://hazmat.dot.gov/68fr-14509.pdf.
- Uniting and Strengthening America by Providing Appropriate Tools Required
to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act), Title X,
Section 1012, enacted by Congress October 25, 2001.
- Transportation Security Administration, Docket No. TSA-2003-14610,
Amendment No. 1572-1, available at
http://www.tsa.gov/interweb/assetlibrary/68_FR_23852.pdf as of 7/3/2003.
- Department of Homeland Security, available from
http://www.dhs.gov/dhspublic/display?theme=29.
- "Most of Stolen Cyanide Drums Found," available at
http://www.CNN.com/WORLD, May 29, 2002.
- U.S. Department of Justice, Federal Bureau of Investigation, "Terrorism in
the United States 1999," 30 Years of Terrorism A Special Retrospective
Edition, 1999.
- Clayton, Bruce D., Life After Terrorism, (Boulder, CO: Paladin Press),
2002.
- U.S. Department of Homeland Security, Information Bulletin 03-004, March
20, 2003.
Appendix F: Helpful Industry Web Sites
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