Field officials with the Federal Motor Carrier
Safety Administration will be reviewing security measures with motor carriers
and shippers that may be the target of terrorist attack. Our mission: To increase
the level of awareness of hazardous materials carriers to terrorist threats. The
FMCSA field staff will be providing information in the form of recommendations
and suggestions, except those regulatory requirements affecting the actual movement
of hazardous materials. Highlights of the Security Talking Points are outlined
below. These recommendations may not apply to all carriers, based on their size
and scope of operation. Additionally, this list is not all-inclusive and will
be changed based on future priorities to address terrorist threats. OPENING
INTERVIEW
Explain
the reason for the visit.
This
information is being offered as suggestions and recommendations. Except where
noted, the security measures being discussed are not required by DOT regulation.
Some of
the information may not be appropriate for all operations, particularly small
operations.
Where
possible, discuss some of the Suspicious Activity Reports that have been generated
as a result of the SSVs that have already been conducted.
Emphasize
that the security talking points should be considered in the hiring and training
of all employees, not just drivers.
GENERAL
SECURITY INFORMATION Recommend
to the carrier that a security plan be developed and implemented. It should include:
Recommend
that management encourage input and participation in the development and implementation
of the company's security program.
Discuss
the fact that any employee could pose a security risk.
Implement
method for security identification (i.e., ID badges). Identification should include
the employee's name, the company name, the employee's picture, and a phone number
where the employee's identification can be confirmed. Companies should establish
systems to control security identification of employees leaving the company.
Review
the list of drivers and request the required number of driver qualification files
for review.
Ensure
that the carrier is complying with the investigation and inquiry requirements
of 49 CFR 391.23. Discuss with the company official any additional checks made,
such as criminal background checks, personal reference checks, credit checks,
etc.
When
reviewing the contents of the driver qualification files, particular attention
should be given to:
Gaps
in employment
Frequent
job shifts
All
names used by the applicant
Type
of military discharge
Citizenship
Present
and prior residence information
Personal
references
Criminal
history
Verify
compliance with the Immigration Reform and Control Act of 1986, in that I-9 forms
are properly completed and maintained for all employees.
Determine
if the company utilizes face-to-face interviews of prospective employees, to obtain
information that will help to appraise personality, character, motivation, honesty,
integrity, and reliability.
Any
information or suspicious activity discovered during the review of these files
should be reported immediately to your SD/DA for possible referral to the local
FBI office.
HAZARDOUS
MATERIALS AND PACKAGE CONTROLS Security enhancements that might be
considered: Are
the facility grounds adequately lighted?
Are
hazardous materials located in a secure area?
Are
transport vehicles located in a secure area?
Is
the access to hazardous materials limited and/or monitored (sign-in/sign-out)?
Consider
requiring employee identification cards/badges.
Consider
other protective measures, such as security alarms, video surveillance, security
services, etc.
Consider
if a guard force is appropriate (DOD Shipments, poisonous by inhalation hazard
materials, radioactive materials, DOE shipments, other).
Require
records for removal of HM from secure locations.
Reinforce
with employees the importance of remaining aware of their surroundings at all
times.
Recommend
standard procedures for control of HM packages, educating all employees on package
control measures. Post procedures prominently at appropriate locations.
Know
whom you are dealing with, including shippers, receivers and vendors that service
your facility.
Limit
and track keys/entry cards, paying special attention to those issued to employees
who are no longer with the company.
Avoid
high population centers, including downtown and/or metropolitan areas, tunnels
and bridges, where possible (see 49 CFR 397.67).
Ensure
that all hazardous materials are delivered expeditiously.
Instruct
drivers to lock vehicles when in transit or unattended.
Reinforce
attendance and parking rules in 49 CFR Part 397.
Drivers
must be aware of vehicles that may be following their truck and strangers asking
inappropriate questions.
Be
suspicious of individuals asking you to stop as a result of an alleged traffic
accident. If unsure whether the accident occurred, drive to a police station or
to a well-lit, busy location before stopping.
Be
cautious about stopping to help stranded motorists or at accident scenes. If possible,
call the State Police instead.
Do
not pick up hitchhikers.
Do
not discuss the nature of the cargo at coffee shops, truck stops, over the CB
radio, etc.
Drivers
must remain aware of their surroundings at all times.
Drivers
should have a means to maintain communication with the company, such as cell phones,
two-way radios, CBs, satellite communication systems, etc.
Make
yourself aware of technical innovations that could assist in security, such as
cell phones, satellite tracking, and surveillance systems.
Look
at state-of-the-art locks and seals.
Are
access control systems appropriate?
Consider
tamperproof locking features for fifth wheels (so that trailers cannot be stolen).
Consider
installing electronic engine controls that require a code, in addition to a key,
to start a vehicle.
Consider
theft-prevention devices, steering locks, fuel cutoff switches, electrical cutoff
switches, and other high-security ignition devices.
Include
fingerprinting (where permitted by law) and photographs of applicants in the employment
process.
Be
aware of personal identity theft, such as using stolen social security numbers,
references, etc.
Consider
running criminal background checks where permitted by law.
Consider
implementing security training for employees that includes:
Company
Security Objectives
Specific
Security Procedures
Employee
Responsibility
Organizational
Security Structure
Develop
a communications network with others in the industry in an effort to share information
to determine if there is a pattern of activities that when taken alone are not
significant, but when taken as a whole generate concern.
Develop
a means of communication within the physical plant and the vehicle (cell phones,
satellite tracking, radios, etc.). Is the system capable of reaching all key personnel?
Security
messages should be presented to employees by various means such as newsletters,
bulletin boards, etc.
READJUSTMENT
BASED UPON CURRENT CONDITIONS Emphasize
that terrorist activities tend to occur in groups. Security should be heightened
if new attacks begin.
Increase
security measures while the U.S. is involved in military activities in foreign
countries.
Increase
security measures when the U.S. is at a heightened state of alert.
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