PHMSA Response Letter

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November 21, 2011

Mr. Jeff Shouse
QA Manager
c/o Waste Control Specialists LLC
9998 Hwy 176 W.
Andrews, TX 79714

Reference No.: 11-0263

Dear Mr. Shouse:

This is in response to your October 25, 2011 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to transportation security plans. Specifically you ask if identified security concerns should be listed or identified within the security plan, or if the security plan should include what measures the facility incorporates to address weaknesses identified during the performance of a risk assessment.

Transportation security plans must contain both an identification of transportation security risks and identify the measures incorporated by the facility to deal with these security risks. The components of a security plan are identified in § 172.802 for those who offer for transportation in commerce or transport in commerce one or more of the hazardous materials listed in § 172.800(b). Section 172.802(a) states that a security plan must include an assessment of transportation security risks and also include appropriate measures to address the assessed risks.

I hope this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

172.802, 172.800