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
I. Next meeting will be on Jan. 21, 2004 at 9 am. The location will be announced
a. Are there gaps in employment?
2. Unauthorized access
b. Actually call 3 character references
c. Confirm that candidate is legal to work in the US
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
5. Incident Reporting
6. Risk Assessment