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DOT has requirements at 49 CFR 177 that are specific to the transportation of hazardous materials on public highways by private, common, or contract carriers that are in addition to the other applicable requirements. These requirements pertain to:
- Training
- Shipping papers
- Emergency situations and accidents
- Loading and unloading
- Segregation and separation of materials
- Carrying passengers for hire
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Here’s a security checklist you can use to double-check your hazmat operations.
Personnel Security
- Encourage your employees to report suspicious incidents or events.
- Implement routine security inspections.
- Convene regular employee/management meetings on security measures and awareness.
- Make sure all employees handling or transporting hazardous materials have adequate communication devices in case of emergency. Test these systems.
- If you have a management crisis team, verify their 24/7 contact information and place them on “ready alert.”
- Ensure that all employees have proper and up-to-date identification.
- Ensure that company personnel monitor news and other information sources for events or changes in conditions and respond as appropriate.
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Facility Security
- Cooperate with federal or local law enforcement officials concerning security checks or safety checks.
- Restrict the availability of information related to your facility and employees, and the materials you handle.
- Restrict access to a single entry or gate. Control who enters and leaves your facility, if possible. Require visitors to show photo identification and have someone accompany visitors at all times.
- Add security guards and increase off-hours patrols by security or law enforcement officials.
- Reduce your internal tolerance for “security anomalies,” such as overdue or missing vehicles, perimeter of physical plant intrusions, unverified visitors, evidence of tampering, and the like.
- Install additional security systems on areas containing hazardous materials, if needed.
- Do not preload hazardous materials shipments.
- Require employees to display identification cards or badges while at the facility.
- Conduct spot checks of personnel and vehicles.
- Test your emergency response communications systems.
- Upgrade security procedures for pick-ups and deliveries. Verify all paperwork and require pick-up and delivery appointments from known vendors. Require pick-up drivers to provide driver’s name and vehicle number—confirm with vendor. Accept deliveries in designated areas only.
- Confirm legitimacy of new vendors through listings in phone book or industry publications, websites, or references.
- Secure hazardous materials in locked buildings or fenced areas. Have a sign-out system for keys.
- Secure valves, manways, and other fixtures on transportation equipment when not in use. Secure all rail, truck, and barge containers when stored at your location.
- Use tamper-resistant or tamper-evident seals and locks on cargo compartment openings.
- Maintain current inventories of on-site hazardous materials and check accounts for shortages or discrepancies.