Hazardous Material Security Training and Testing for CDL Drivers and HAZMAT Employees

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1 Hazardous Material Security Training and Testing for CDL Drivers and HAZMAT Employees The United States Department of Transportation s Research and Special Programs Administration (RSPA) issued final regulations (FR ) requiring all companies that transport (or arrange for transportation) and store hazardous materials (including petroleum products) establish a written security plan. A key component of the new federal regulations involves security training. The new regulations do not require that all company employees undergo security training. Instead, only CDL drivers with a hazardous materials endorsement and other designated HAZMAT employees employees that directly handle or have access to hazardous materials must undergo security training. It is easy to identify those employees who must be trained under the new security regulations. If the employee is already required to undergo HM-126 hazardous material safety training, then that employee must also undergo security training. IMPORTANT: The new regulations offer little guidance on security training procedures. There are no specific tests or detailed curriculum established within the security training regulations. Instead, the U.S. DOT has established a performance standard for training that must be met. Exactly how you meet the training performance standard is left largely up to you. Specifics on how to meet the security training standards are discussed below. TRAINING STANDARDS: There are two types of security training standards required under the new security regulations: 1. Security Awareness Training - The first training standard requires drivers and HAZMAT employees to undergo security awareness training. The U.S. DOT regulations simply state that this type of training must: provide an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats. No specific training requirements or curriculum is provided under the regulations. However, it is not necessary for this training to be performed in-house. Instead, the U.S. DOT requires that security awareness training be integrated into the current HM-126 safety training curriculum that drivers and other HAZMAT employees must already undergo every three years or within 90 days of hire pursuant to the federal hazardous materials transportation regulations. Furthermore, no special training date must be scheduled to meet the security awareness training standard. Under the new security regulations, the deadline for security awareness training is the date of the driver s or HAZMAT employee s next regularly scheduled HM-126 safety training. All drivers and HAZMAT employees must complete this component of the security training no later than March 25, 2006 (This date marks the end of one complete three-year HM 126 safety training cycle from the date the final security rule was published by the DOT). You should double-check to make sure that your HM-126 trainer has added the security awareness training component to the course curriculum. 2. In-depth Security Training - The second type of training, also limited to drivers and designated HAZMAT employees, is in-depth security training on the specifics of the company s written security plan. This training standard must familiarize drivers and HAZMAT employees with the specific provisions within your written security plan including company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach and the

2 company s organizational security structure. This training component may met by having drivers and HAZMAT employees read your written security plan, acknowledge in writing that they fully understand its provisions, and will implement the plan requirements at all times and take a simple written exam on the specifics of the written security plan. This component of training must be completed by December 22, It would also be beneficial, for you and your employees to spend some time simply talking about the specifics of the company s security plan. This can be done before or after the written examination and may include hypothetical security situations that employees are asked to respond to. Topics such as risk awareness and response procedures should be covered in the oral discussion. ATTACHMENTS: The following documents necessary to complete your security training program are attached. Exam - Generic HAZMAT security examination designed to test driver s and designated HAZMAT employee s specific knowledge of your company s written security plan. This exam is written to cover the operational activities (transportation by cargo tank vehicle and bulk plant transfer activities) of a typical petroleum marketing operation. You should edit this exam to fit the requirements of your own security plan and the type of operational activities in which you are engaged. The examination should take about 30 minutes to complete. The completed exam should be kept in a centralized security file. Answers - A list of answers to the generic HAZMAT security examination questions. The DOT imposes no pass/fail requirement or any other minimum score level on the test. The regulatory requirement is simply that a test be given to measure knowledge of the written security plan. Of course, it is to your benefit that drivers and designated HAZMAT employees do well on the test. The test should be dated, signed by the exam taker and kept in a central security file. Talking Points - A list of talking points that may be used in an oral discussion with drivers and HAZMAT employees, either before or after the written exam, on the specifics of your company s written security plan and general security issues. While an oral discussion is not required, it should be included in the training program so that drivers and designated HAZMAT employees have the opportunity to ask any questions they may have regarding the specifics of the written security plan. The oral discussion should take about 30 minutes to complete. Acknowledgement Forms An acknowledgement form is attached for driver s and designated HAZMAT employee s attesting to their knowledge and understanding of the company s written security plan. Another acknowledgement form for general awareness security trainers is also included. The forms should be signed and kept in a central security file. Certificate of Training - A simple certificate that acknowledges that the in-depth security training has been completed. This certificate should be kept in a centralized security file. See Attachments Below

3 Hazardous Material Drivers and Employees Hazardous Material Security Training Examination For Testing In-depth Knowledge of the Company s Written Security Plan The following examination is designed to test the exam taker s in-depth knowledge of the company s written security plan. Before you take this test, read and familiarize yourself with the company s security plan that has been provided to you. The U.S. Department of Transportation requires that you have in-depth knowledge of the company s security plan. Section One: Personnel Information: Please Print. Name CDL License Number Job Tile and/or Description Section Two: Please Answer the Following Questions 1. What is the purpose of the Company s written security plan? 2. Who do you contact to report suspicious activity or specific security events? 3. When is it permissible to render roadside assistance during delivery to motorists or other individuals in need? 4. What is the procedure for securing the cargo tank motor vehicle while loading or unloading product?

4 Page 2. In-depth Security Awareness Examination 5. Where is the security procedure for unattended parking of the cargo tank motor vehicle during the delivery run? 6. What is the security procedure for engaging in conversation while making deliveries? 7. What is the security procedure for parking and securing the cargo tank motor vehicle at the end of the delivery run? 8. What is the security procedure for pre-trip inspections? 9. What is the security procedure if you are delayed along the delivery run by traffic, long lines at the terminal or similar events? 10. What is the security procedure for bulk plants? 11. Are deviations from the delivery run allowed and if so under what circumstances?

5 Page 3. In-depth Security Awareness Examination 12. What suspicious activities should you look for while on the delivery run? 13. What suspicious activities should you look for while loading and unloading at the bulk plant? 14. Who should you report a security event or suspicious activity to and when? 15. Who is authorized to have access to the cargo tank vehicle cab? 16. Who is authorized to have access to bulk plant facilities? 17. Who do I talk to if I have questions or suggestions regarding the company s security plan? Sign Name Here Date. Keep the original signed copy of this document in the company s security file.

6 Hazardous Material Drivers and Employees Hazardous Material Security Training Examination For Testing In-depth Knowledge of the Company s Written Security Plan Examination Answers: 1. What is the purpose of the company s written security plan? A. The purpose of the company s written security plan is to develop and implement procedures to address security risks related to the transportation of hazardous materials. The written security plan describes security procedures that must be followed to reduce the risks of unauthorized persons gaining access to hazardous materials stored in the bulk plant facility and while en-route in a cargo tank motor vehicle from the point of origin to the final delivery destination. 2. Who do you contact to report suspicious activity or specific security events? A. I must immediately report all security events and suspicious activities to the company s designated security manager/coordinator. 3. When is it permissible to render roadside assistance along the delivery route to motorists or other individuals in need? A. Never. Stopping to provide roadside assistance increases the risk that the cargo tank motor vehicle may be hijacked and used as a weapon of mass destruction by terrorists. Instead, if a motorist or other individuals along the delivery route needs emergency assistance, I may, at my discretion use my cell phone to notify the local police. 4. What is the procedure for securing the cargo tank motor vehicle while loading or unloading product? A. During each delivery I must, turn off the cargo tank motor vehicle s engine, roll up the cab windows, remove the keys from the ignition, take my cell phone and lock the cab doors. 5. Where is the security procedure for unattended parking of the cargo tank motor vehicle during the delivery run? A. If I must stop along the delivery route for a bathroom break, rest period or meal, the cargo tank motor vehicle must be securely locked, parked in a well lit public area offering -1-

7 unobstructed views that allow me to maintain visual contact at all times. I must immediately notify the dispatcher whenever the vehicle is to be left unattended and make every attempt to minimize the time I spend away from the vehicle. 6. What is the security procedure for engaging in conversation while making deliveries? A. Conversations other than with authorized persons at the point of delivery are forbidden. Conversations with unauthorized persons or strangers, however harmless they may seem, could create a distraction that would allow unauthorized access to the vehicle and/or shipment. 7. What is the security procedure for parking and securing the cargo tank motor vehicle at the end of the delivery run? A. The cargo tank motor vehicle must be fully secured. The cab windows must be rolled up, keys removed from the ignition, cab doors locked and all valves and other conveyance equipment secured. The vehicle may only be parked in authorized areas designated by the company. Vehicle keys must be turned into to the dispatch office where they are held in a secure place until the next scheduled delivery. 8. What is the security procedure for pre-trip inspections? A. I must perform a walk around inspection of the vehicle before each trip to detect signs of tampering with and/or vandalism to any equipment, including tires, tank shell, bulkhead, valves piping and manhole devices. Any signs of tampering or vandalism must be reported immediately to the company s designated security manager/coordinator. 9. What is the security procedure if you are delayed along the delivery run by traffic, long lines at the terminal or similar events? A. I must notify the dispatcher immediately of any delay. 10. What is the security procedure for bulk plants? A. During loading and unloading, I must ensure that all equipment at the bulk plant including loading arms, valves and gates are fully secured. Signs of tampering, vandalism or unauthorized persons gaining access to the bulk plant storage facility must be reported immediately to the company s security manager/coordinator. Also, I must follow the same procedures to secure the cab when loading and unloading at a bulk plant as is required during customer delivery. 11. Are deviations from the established delivery route allowed and if so under what circumstances? A. Deviations from the established delivery route are allowed only when necessary for an authorized business purpose or emergency situation. Any deviation must be reported immediately to the dispatcher. -2-

8 12. What suspicious activities should you look for while on the delivery run? A. I should be aware of and avoid any person that approaches me and strikes up a conversation, particularly one that relates to the contents of the cargo tank motor vehicle, delivery routes or customer information. I should also be aware of any tampering or vandalism with the cargo tank motor vehicle, any person taking photographs of the vehicle or equipment, persons driving in passenger vehicles attempting to wave me to the side of the road, lost, stolen or missing product, equipment or paperwork and any other event that seems suspicious. In every case where my suspicions are aroused, I must immediately report the information to the company s designated security manager/coordinator. 13. What suspicious activities should you look for while loading and unloading at the bulk plant? A. Signs of vandalism or tampering with bulk plant equipment, the presence of unauthorized persons, suspicious individuals in the vicinity of the bulk plant who may be observing loading and unloading activities or anyone taking photographs of the facility or showing unusual interest in information about the bulk plant and any lost, stolen or missing product, equipment or paperwork. In every case where my suspicions are aroused, I must immediately report the information to the company s designated security manager/coordinator. 14. Who should you report a security event or suspicious activity to and when? A. All reports regarding security related issues must be reported immediately to, the company s designated security manager/coordinator. 15. Who is authorized to have access to the cargo tank vehicle cab? A. Only those persons specifically authorized by the company or by law to have access may enter the cab. I may never allow access into the cargo tank vehicle cab to any person not an employee of the company, employees not authorized to have access to the vehicle cab, friends, family, or strangers including hitchhikers or any person asking for a lift. 16. Who is authorized to have access to bulk plant facilities? A. Only those specifically authorized by the company or by law to have such access. I may never allow access to the bulk plant facility to any person not an employee of the company, employees not authorized to have access to the vehicle cab, friends, family, or strangers. 17. Who should you talk to if you have questions or suggestions regarding the company s security plan? A. I may talk to the company s designated security manager/coordinator at any time concerning questions that I may have regarding the written security plan, security risks, security awareness or any other security related issue. I am also encouraged to make security suggestions that will enhance the security of the shipment or storage of the hazardous material. -3-

9 Hazardous Material Security Training and Testing Suggested Talking Points: The U.S. DOT regulations do not require extensive training to meet the in-depth security training standard. However, a brief 30-minute discussion with drivers and HAZMAT employees concerning security issues is helpful not only to promote greater understanding of the topic, but also to demonstrate that you have implemented a well-rounded training program. The following talking points may be used to conduct the discussion session. DISCUSSION TOPICS: What do you see as the greatest security risk to product at the bulk plant or along the delivery route and how can the identified risks be reduced? Do you think it is likely that products such as gasoline or diesel fuel will be used as a weapon of mass destruction in this country? How about in our town? Do you think it would be advantageous or disadvantageous for a terrorist group to target a cargo tank vehicle and or bulk plant in our area? What are the potential targets that terrorists might find attractive in this area, specifically along our delivery routes? Can you be sure that a terrorist attack against in our town, using company product and equipment could never happen? What kinds of weapons of mass destruction do you think can be made from gasoline, diesel fuel or other petroleum products? Have you ever heard or read about any instances where petroleum product was used as a weapon of mass destruction in the U.S. or any other country? What do you think about the company s written security plan? How can it be improved? Is there anything in the security plan that will make you job more difficult or time consuming? Do you have any questions relating to the written security plan, the plan requirements, potential security risks or your responsibilities in the event of a security incident? Keep a copy of this document in the company s security file.

10 Employee Acknowledgement of Company s In-depth Written Security Plan Requirements. I have read the company s written (employee name) security plan and have an in-depth knowledge of its requirements. I fully understand the risks associated with the transportation of petroleum products. I am able to identify and respond to security risks pursuant to the company s written security plan. If at any time my awareness of security issues becomes unclear or insufficient, I will seek clarification from the company s designated security manager/coordinator. I also understand that upon request, the company will provide me with the additional training necessary to correct my level of awareness. I understand that the company s written security plan is binding company policy that I must follow at all times and that any breach of the company s security procedures may result in termination of employment. Employee Signature Date Designated Security Manger/Coordinator Signature Date Keep the original signed copy of this document in the company s security file.

11 Certificate of Completion In-depth Security Training on Company s Written Security Plan This Certificate certifies that has completed in-depth security awareness training on the company s written security plan as required by United States Department of Transportation regulations 49 CFR (The Hazardous Materials Communications, Emergency Response Information and Training Requirements). The training course included a written examination and oral discussion concerning the company s security objectives, organizational security structure, specific security procedures, employee responsibilities and actions to be taken in the event of a security breach. Safety Manger/ Coordinator Date Keep the original signed copy of this document in the company s security file. See next page

12 Acknowledgement of Security Awareness Component in HM-126 Hazardous Material Safety Training Course The United States Department of Transportation s Research and Special Programs Administration (RSPA) issued a final regulation (FR ) requiring all companies that transport or arrange for transportation of hazardous materials to establish a written security plan. A key component of the new federal regulation requires that CDL drivers with hazardous materials endorsements and other HAZMAT employees undergo security training (49 CFR ). A major component of the training provision under the new regulation requires CDL drivers and other HAZMAT employees to undergo security awareness training. The U.S. DOT regulations simply state that security awareness training must: provide an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats. The U.S. DOT requires that security awareness training be integrated into the current HM-126 training curriculum that drivers and other HAZMAT employees must undergo every three years or within 90 days of employment. Under the new security regulation, the deadline for security awareness training is the date of the driver s or HAZMAT employee s next regularly scheduled HM- 126 training. All drivers and HAZMAT employees must complete this component of the security training no later than March 25, Please sign below acknowledging that the HM-126 training course you provide includes the new security awareness training component as mandated by the U.S. DOT. I, acknowledge that the HM-126 training course Training Provider Representative conducted by on behalf of Training Provider Company Training Purchaser fully complies with the security awareness training component required by the United States Department of Transportation pursuant to 49 CFR Signature of Trainer Provider Representative Date Keep the original signed copy of this document in the company s security file.