HELP Meeting Minutes
November 19, 2003
Hosted by Berlex and Donna Hoskins

I. Guest Speaker: Matt Moeller    
University of Washington

Topic: HM 232 Security Plans: Hazardous Materials Transportation Security
Disclaimer: Matt is not an attorney and he is not speaking for UW

HM-232 was published and effective 3/25/03. This ruling spells out the requirements for security plans for shipment of hazardous materials. You need a security plan if you ship any of the following:
1. A highway route-controlled quantity of a Class 7 Radioactive
2. More than 25kg of a Division 1.1, 1.2, or 1.3 Explosive
3. More than 1L of a material poisonous by inhalation for Zone A
4. Bulk packaging with a capacity equal to or greater than 3500 gal. For liquid or 468 cubic feet for solids
5. Other than bulk packaging equal to or greater than 5000lbs. of one class for which placarding would be required.
6. A select agent or toxin as defined by 42 CFR part 73.
7. A quantity of hazardous material that requires placarding.
 
All haz mat employees need security awareness training even if the site does not need a security plan. Do your employees know what to do if they see someone suspicious? Are all areas secured?
The security plan’s format is not defined by the DOT. It will be based on security risk assessment. It should cover unauthorized access, personnel, and en route security issues. The format is flexible to allow for differing circumstances. See http://hazmat.dot.gov for additional information.
If your site needs a security plan, the following items must be addressed:
1. Personnel-Hiring Process
a. Are there gaps in employment?
b. Actually call 3 character references
c. Confirm that candidate is legal to work in the US
2. Unauthorized access
3. En Route Security-Obtain security plans from your shippers and handlers of hazardous materials
4. Evaluation-There needs to be a process for updating the plan as any circumstances change
5. Incident Reporting
6. Risk Assessment
 
I. Next meeting will be on Jan. 21, 2004 at 9 am. The location will be announced