Introduction The US Department of Transportation mandates security awareness training as part of their security requirements found in Subpart I of Part 172 of the Hazardous Materials Regulations. The requirement is predicated on the need for a written transportation security plan. This module, which includes a short quiz, is designed to meet those training requirements. Upon completion of the module, you will be issued an electronic training certificate. The Security Requirements of DOT The US Department of Transportation mandates security awareness training for all hazmat employees. The definition of a hazmat employee is located in 49 CFR 171.8. As implied, awareness training is designed to point out that many hazardous materials are essential products to industry, but could be potentially used as a weapon. However certain materials are known as high consequence hazardous materials. The list of these items is found in 49 CFR 172.800. does have such materials onsite. These materials mandate f a Transportation Security Plan. You should have a copy of this plan in order to complete this module. Once the plan has been written, in depth security training must be conducted in the plan. At a minimum, a security plan must have the following components: (49 CFR 172.802) (a) The security plan must include an assessment of transportation security risks for shipments of the hazardous materials listed in 172.800, including site-specific or location-specific risks associated with facilities at which the hazardous materials listed in 172.800 are prepared for transportation, stored, or unloaded incidental to movement, and appropriate measures to address the assessed risks. Specific measures put into place by the plan may vary commensurate with the level of threat at a particular time. At a minimum, a security plan must include the following elements: (1) Personnel security. Measures to confirm information provided by job applicants hired for positions that involve access to and handling of the hazardous materials covered by the security plan. Such confirmation system must be consistent with applicable Federal and State laws and requirements concerning employment practices and individual privacy. (2) Unauthorized access. Measures to address the assessed risk that unauthorized persons may gain access to the hazardous materials covered by the security plan or transport conveyances being prepared for transportation of the hazardous materials covered by the security plan. (3) En route security. Measures to address the assessed security risks of shipments of hazardous materials covered by the security plan en route from origin to destination, including shipments stored incidental to movement. (b) The security plan must also include the following: www.haztraining.com Page 1
(1) Identification by job title of the senior management official responsible for overall development and implementation of the security plan; (2) Security duties for each position or department that is responsible for implementing the plan or a portion of the plan and the process of notifying employees when specific elements of the security plan must be implemented; and (3) A plan for training hazmat employees in accordance with 172.704 (a)(4) and (a)(5) Designated Security Contact Windom All security related questions, information, and reports of suspicious activity or incidents involving the shipment of HM the Windom site must be reported immediately to: Tim Hiley 507.831.0340 The designated security contact will relay security related information immediately to the appropriate person or persons within The Toro Company as well as to state local and federal law enforcement officials if appropriate. In the case of a security emergency or incident, all information must be relayed immediately by the individual responsible for HM s storage and/or shipment security to appropriate parties and authorities. The designated Toro Company Security Contact must immediately alert state and local police authorities and the local Office of the FBI of any security incident involving any violation of this SP, potential terrorist act or threat and/or other HM incidents believed to be associated with terrorist organizations. The following emergency contact and/or first responder numbers should be called in the event of a terrorist act: Contact Information: For Emergencies: emergency contact and/or first responder numbers should be called in the event of a terrorist act: General: Dial 911 Includes Windom Fire and Police Other Contact Information: FBI Minneapolis 1501 Freeway Blvd. Brooklyn Center, MN 55430 763 569 8000 www.haztraining.com Page 2
Personnel Security Page 9 of the plan addresses security requirements for personnel with access to hazardous materials storage areas, or those who receive these materials. Please note carefully the procedures to ensure that hazmat employees do not pose a security risk that in any way endangers a shipment or storage of hazardous materials. Such procedures include: Ensure that a background check for criminal activity and security risk is performed on all applicants for HM employees; Contact previous employers and references of all applicants for HM employees; Investigate gaps in applicant employment history or any other information that seem suspicious, To the extent possible, require at least ten years consecutive employment and/or education records for all HM employees and applicants. Ensure HM driver applicants have current CDL license with appropriate endorsement and other forms of identification (e.g. current medical qualification certificates, etc.), Verify that all HM employees and potential applicants for those positions are US citizens, or have appropriate legal alien status and work authorization documents issued by the U.S Immigration and Naturalization Service, Upon termination of employment of any HM employees; check out with facilities management, security and the environmental health and safety office prior to departure. The purpose of which is to ensure the following requirements are competed: Collecting employee identification cards, photos or other items that demonstrate Un Collecting any company owned cell phones and/or two way radios; Canceling all computer passwords and other access codes that would allow former employees to gain access to HM shipments or to sensitive information such as delivery schedules, routes and destination; Updating company records, web sites and other material that lists employees names and removing their names and/or authorized access to HM storage areas or shipments, Informing coworkers and other company personnel and employees, information technology personnel, product suppliers, and other appropriate department personnel when a former employee is no longer authorized to access, ship or receive HM shipments. www.haztraining.com Page 3
Unauthorized Access Preventing unauthorized persons from gaining access to hazardous materials storage areas is imperative. Page 10 of the plan outlines procedures to be followed to prevent unauthorized access to areas and locations where hazardous materials are stored: All outside visitors and vendors that are required to enter facilities where HM are present must be known to The Toro Company employee or be able to produce photo identification; All containers throughout the site which house HM must be secured by lock and key, Keys will be stored in a secure area when unattended or not in use. All vehicles and related equipment containing or transporting HM will be adequately secured by lock and key at all times while on site. Keys must be kept in secure areas. Random and periodic inspections of trucks, vehicles and storage areas where HM are located will be conducted on a random basis to detect evidence of tampering, vandalism and to further demonstrate that The Toro Company has an active terrorism deterrent program in place; Trucks and vehicles will not be left unattended in unless secured by lock and key. Access to information regarding delivery schedules, routes and destinations must be limited to employees on a need to know basis. HM shippers, receivers and drivers will be provided with periodic information on security precautions and other terrorist and national security concerns; and More stringent security precautions to prevent unauthorized access may be required when the nation s threat level increases. Enroute Security Page 11 of the plan outlines procedures to enhance the security of hazardous materials during shipments. All transportation companies utilized will be reviewed to ensure that their Security Plans address the following elements: HM drivers will be required to conduct an inspection of their truck and/or vehicles for any unauthorized alterations, tampering or any other suspicious activity. This inspection will be conducted at the beginning of each shift as a part of normal daily pre-trip vehicle inspection, HM drivers will conduct a walk around inspection of the transporting vehicle after each delivery or stop to ensure that no unauthorized alteration, tampering or other suspicious activity has occurred. At any time which the HM driver leaves the truck or transporting vehicle (e.g., break time, down time, end of shift, etc.) they must ensure that the keys are removed from the ignition, the www.haztraining.com Page 4
windows are fully rolled up and the doors are locked and secured, HM drivers are forbidden to pick up hitchhikers, allow any unauthorized person in the truck cab, stop for motorists in distress or pull over at the behest of any person unless instructed to do so by a law enforcement official, HM drivers must notify the dispatcher when deliveries fall more than one hour behind schedule e.g., traffic delays. Whenever a HM driver parks a motor vehicle for any reason other than loading or unloading, they must ensure that the vehicle is parked in a well lit and safe area with reasonable visibility and security, HM drivers should make every effort practicable, in order to minimize down time during the assigned delivery route, HM drivers should not talk to unauthorized persons about the delivery route, delivery schedule or ultimate destination of any HM shipment, HM drivers should remain continually alert for any suspicious activities that may endanger the shipment (e.g. talkative strangers inquiring about the shipment, roadside distractions such as disabled vehicles, occupants of vehicles pulling alongside the cargo tank motor vehicle attempting to catch your attention or distract you. Be especially aware of vehicles with three or more male occupants). Vulnerability Assessments A vulnerability assessment will be conducted for each identified risk that ranks the risk according to DOT guidelines. Each risk will be ranked according to hazard and exposure where the hazard ranking considers various chemical properties. The exposure ranking includes conditions such as predictability of shipments, proximity to public events, volume, population densities, trip distance and environmental conditions. The risk and vulnerability assessments will be maintained separately and will only be released to authorized personnel. Training Requirements Please consult pages 12 and 13 of the security plan for training requirements. www.haztraining.com Page 5