In March 2003, the Department of Transportation (DOT) issued regulations to enhance the security of hazardous materials transported in commerce. These regulations, known as HM-232, require shippers of certain hazardous materials to develop and adhere to a transportation security plan and train relevant employees regarding the security plan. In March 2010, DOT issued a Final Rule Adjustment, narrowing the scope of hazardous materials subject to HM-232 and modifying certain security plan components and training requirements.
The security plan must include a site-specific transportation security risk assessment and appropriate measures to address the assessed risks. Additionally, each security plan must include the following components:
- Personnel Security – Measures to confirm information provided by job applicants hired for positions that involve access to and handling of the hazardous material(s) covered by the security plan;
- Unauthorized Access – Measures to address the assessed risk that unauthorized persons may gain access to the hazardous material(s) covered by the security plan; and
- En Route Security – Measures to address the assessed security risks associated with shipments of the hazardous material(s) covered by the security plan en route from origin to destination, including shipments stored incidental to movement.
The HM-232 regulation applies not only to those who transport the hazardous materials, but also to the facilities that offer the hazardous materials to third party drivers and rail carriers.
