Security Plans (21)
Criticality: Medium
Progress: Addressed, Not Adequately
Score: 12
DOT Relevance: §172 Subpart I
Description of Key Area
This key area pertains to security plans that are required for
the transportation of hazardous materials such as would be required by the fuel
supply infrastructure supporting hydrogen fueled vehicles under most scenarios.
These requirements are specified in §172.800 (Purpose and Applicability), §172.802 (Components of a Security Plan),
and §172.804 (Relationship to Other Federal Requirements). Review of the
applicability provisions in §172.800 indicates that these DOT security
plan regulations would apply to many of the fuel-supply infrastructure
scenarios being considered as candidates for commercialized hydrogen fueled
vehicle operations.
Discussion of Criticality
This key area is judged to be of medium criticality because the
regulations contained in §172.800,
§172.802, and §172.804 appear to be appropriate and
directly applicable to potential hydrogen vehicle fuel-supply infrastructure requirements,
and because it is anticipated that organizations that might transport hazardous
materials as part of such an infrastructure will be experienced in this area
and capable of addressing the security plan requirements.
Discussion of Progress
Progress toward developing security plans for hazardous material
transportation as part of hydrogen vehicle fuel supply infrastructure is rated
at “Addressed, Not Adequately.” This is because, as mentioned above, it is
anticipated that organizations responsible for hydrogen vehicle fueling
infrastructure hazardous material transportation will be able to meet the
security plan requirements. Moreover, it is anticipated that some existing
hazardous materials transportation security plans are partially applicable, although
this has not been verified.
ASME Innovative Technologies Institute, LLC is working on a new
standard for Risk Analysis Methodology for Critical Asset Protection (RAMCAP). This
new standard may be applicable to many of the security issues discussed. The
standard is expected to be available by the end of 2006.
Recommendations
It is recommended that the development of hydrogen vehicle
commercialization should be monitored with emphasis on the fuel supply
infrastructure in general and any unique security planning requirements in
particular. Any need to refine 49 CFR 172.800, §172.802, or §172.804
should be assessed, and potential programs to support security planning work
should be considered. At a higher level, if and when it appears that hydrogen
vehicles will be commercialized, DOT, the Department of Homeland Security, and
perhaps responsible state agencies should cooperate to determine if there are
any new or special security issues that should be addressed.
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