TOOLKIT FOR Hazardous Materials Transportation Education

1. TOOLKIT FOR Hazardous Materials Transportation Education

2. This work is sponsored by the U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA).  It was conducted through the Hazardous Materials Cooperative Research Program (HMCRP), which is administered by the Transportation Research Board of the National Academies. • Prepared by • 3 Sigma Consultants, LLC • 909 Edenbridge Way, Nashville, TN 37215 Module 7: Security of Hazmat Transportation Shipments

3. Learning Outcomes At the end of this module students will be able to: • Explain the threats posed against hazmat during all phases of transport. • Locate the key regulations governing the security of dangerous goods shipments. • Describe the general principles of ensuring hazmat shipment security. • Illustrate specific examples of security measures for each mode of transportation.

4. Topics • Transportation system security concepts • Regulatory requirements for hazmat shipment security • Motor carrier security • FMCSA Field Operational Test of hazmat safety and security • Rail security • Maritime security • Air cargo security • Pipeline security • Customs‐Trade Partnership Against Terrorism (C‐TPAT)

5. Role of Transportation • Resource • Response • Evacuation • Recovery • Target • Weapons delivery Source: Volpe National Transportation Systems Center

6. Securing Assets in Transport • Ritter et al, Securing Global Transportation Networks, McGraw-Hill, 2007, Chapter 6 • Five Focus Areas: • Maintain chain of custody • Confirm security practices of partners in chain • Verify credentials of personnel in chain • Verify controlled physical access to assets • Emergency preparedness/resilience/redundancy

7. General Principles of Dangerous Goods Security • Natural disasters and theft are greater threats than terrorism and use of hazmat as weapons of mass destruction (WMDs), although the latter should not be ignored. • Measures that improve cargo security in general are equally applicable to hazmat shipment security. • There are some hazmat-specific security requirements and programs.

8. USDOT Hazmat Security Regulations • 49 CFR § 172.800-822 requires development and implementation of plans to address security risks related to the transportation of hazardous materials in commerce. • § 172.800 lists specific quantities of various hazard classes/divisions that trigger this requirement. • Components of a security plan (§ 172.802): • assessment of transportation security risks, including site-specific risks where materials are prepared for transport, loaded, or stored incidental to transport • personnel, unauthorized access, and en route security measures • job title of the senior management official responsible for overall development and implementation of the security plan • security duties for each position or department that is responsible for implementing the plan • plan for hazmat employee security training • § 172.820 requires additional planning for transportation by rail, primarily related to dangerous goods routing (see module 4).

9. USDOE Hazmat Security Regulations • DOE requires establishment and maintenance of a physical system for protection of special nuclear material at fixed sites and in transit, and of plants in which special nuclear material is used. • The system must protect against acts of radiological sabotage and prevent the theft or diversion of special nuclear material. • The in-transit protection must include: • en route telephone or radio communication • minimization of transit time • screening of employees involved in transport • See 10 CFR Part 73 for complete details

10. Security Guidelines for the Transportation of Certain Hazardous Materials Cargo by Commercial Motor Vehicles

11. Applicability of These Guidelines • Radioactive Materials – A highway route-controlled quantity of a Class 7 (radioactive) material, as defined in Section 173.403 of the Hazardous Materials Regulations; • Explosives – More than 25kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material; • Toxic by Inhalation (Division 2.3 and 6.1) Materials • A shipment of compressed or refrigerated liquid methane or natural gas or other liquefied gas in a bulk packaging having a capacity equal to or greater than 13,248 L (3,500 gallons) for liquids or gases. Source: Transportation Security Administration

12. Management Guidelines • Company Security Plans • Security Awareness • Security Plan Maintenance Expectations • Reporting Information Source: Transportation Security Administration

13. Operational Guidelines • Facilities • Shippers • Drivers • Terminals • Consignees Source: Transportation Security Administration

14. Hazmat Facilities • Security measures should make it as difficult as possible for a terrorist to interfere with your company’s transportation operations and cargo within your facilities. • Secure all entry and exit points of your facility. • Develop and maintain an employee ID program. • Erect and maintain security fencing around the perimeter of your property. • Keep entry doors and entrances secure and locked if fire codes permit. • Have visitors sign-in and show ID and wear a visitor pass. Maintain the visitor roster for 12 months. Source: Transportation Security Administration

15. Hazmat Shippers • During cargo loading, monitor loading and to the extent operations allow, provide carrier with a safe and secure location for loading. • Establish an overdue time for the carrier at final destination and follow up when the carrier is late for final delivery or overdue at in-transit points on their route. • When a carrier exits your facility, be aware of any possible surveillance of your facility, or inappropriate behaviors or actions that may occur during this time. • Remind the carrier about established stopping and parking procedures, and caution them not to make any unscheduled stops. • Be aware of possible “ruses.” If you are unsure if a police officer is real, call 911 and ask. Source: Transportation Security Administration

16. Hazmat Drivers • When leaving a facility, be aware of any possible surveillance of the facility or truck. Criminal surveillance often begins at, or within a mile of trip origin. • Have a communication device with you at all times. • Do not make any unscheduled stops. • Report any suspicious activities or emergencies to law enforcement authorities. • Report any suspicious activities to dispatch. • Remain particularly observant for suspicious activities in and around refueling locations, intermodal terminals, bridges, and tunnels. Source: Transportation Security Administration

17. FMCSA Field Operational Test • Objective -- quantify the security costs and benefits of applying technology and improved enforcement to selected hazmat transportation risk areas: • Driver verification • Off-route vehicle alerts • Stolen vehicles • Unauthorized drivers • Cargo tampering • Suspicious cargo deliveries • Conducted in 2002-2003

18. FOT Framework Source: FMCSA

19. Selection of Technologies for Operational Scenarios Source: FMCSA

20. Source: FMCSA

21. Panic Buttons Dash-mounted Panic Button Wireless Panic Button Source: FMCSA

22. Biometric Identification Source: FMCSA

23. Remote Cargo Locks Source: FMCSA

24. Electronic Cargo Seals Smart Seal Tag Source: FMCSA

25. Geofencing Source: FMCSA

26. Trailer Tracking Tethered Device Trailer Tracking Subsystem Source: FMCSA

27. Some FOT Results Source: FMCSA

28. Summary of FOT Findings Source: FMCSA

29. TSA HME Threat Assessment Program • The Patriot Act (2001) prohibits states from issuing a license to transport hazardous materials in commerce unless a determination has been made that the driver does not pose a security risk. • The TSA HME Threat Assessment Program conducts a security threat assessment for any driver seeking to obtain, renew, or transfer a hazardous materials endorsement (HME) on a state-issued commercial drivers license (CDL). • The risk assessment include checks of criminal history records, legal status, and relevant international databases. Source: Transportation Security Administration.

30. Rail Security Issues • Open access and high ridership (passenger rail) • Types and volumes of hazardous materials shipped on freight rail • Interconnectivity of the rail system Source: Federal Railroad Administration, Federal Railroad Administration Action Plan for Addressing Critical Railroad Safety Issues. May 16th 2005

31. Steps Taken to Improve Rail Security since 9/11 • Perform risk assessments • Conduct emergency drills • Develop security plans • Security Training Images from Transportation Security Administration and Federal Transit Administration.

32. Requirements for Rail Carriers of Hazmat • Compile data, by route and line segment, on geographic location of hazmat routes and the total number of shipments by UN number. • Identify practicable alternative routes. • Identify security risks to high-consequence targets along the hazmat routes. • Analyze the safety and security risks for the railroad facilities and high-consequence targets along the routes. • Compare the safety and security risks on the primary and alternative routes. • Use the analysis described above to select the practicable route posing the least overall safety and security risk.

33. Additional Requirements for Hazmat • Conduct a comprehensive review of route selection determinations every 3 years. • In developing security plans required under the HMR, address the security risks of shipments delayed or temporarily stored in transit. • Notify consignees of any significant unplanned delays affecting the delivery of the hazmat. • Work with shippers and consignees to minimize the time a rail car containing hazmat is placed on track awaiting pick-up, delivery, or transfer. • Conduct security visual inspections at ground level of rail cars containing hazardous materials to check for signs of tampering or the introduction of an IED.

34. TSA Rail Transportation Security Requirements • 49 CFR Part 1580, applies to shippers, receivers, and carriers of rail security sensitive materials shipped by rail • Imposes following principal requirements on these parties: • Must allow TSA/DHS to inspect operations for compliance with security directives • must designate and use a primary and at least one alternate Rail Security Coordinator (RSC) • must have procedures in place to determine the location and shipping information for each rail car under its physical custody and control that contains rail security-sensitive materials [see § 1580.103 (3)(c)] • must immediately report potential threats and significant security concerns to DHS by telephoning the Freedom Center at 1-866-615-5150.

35. TSA Chain of Custody and Control Requirements • A rail hazardous materials shipper, carrier, or receiver transferring custody of a rail car containing rail security-sensitive materials must: • physically inspect the rail car before loading or unloading for signs of tampering, including closures and seals; other signs that the security of the car may have been compromised; suspicious items or items that do not belong, including the presence of an improvised explosive device • keep the rail car in a rail secure area until the carrier or receiver takes physical custody of the rail car • not leave the rail car unattended in a non-secure area at any time during the physical transfer of custody • document the transfer of custody • See § 1580.107 for exact duties imposed on the various parties, both within and outside of a high threat urban area (HTUA).

36. Asset/Cargo Tracking • Attributes • Real-time tracking through intermodal chain • Focus on assets & cargo • Internet based information distribution • Purpose • Data availability through intermodal logistics information management system • Real-time cargo and transport asset information • Origin-destination asset and cargo security

37. Maritime Security

38. Port Security Challenge • Over 95 percent of the nation’s overseas cargo moves through our ports. • In 2003, there were 76 million recreational boaters in the United States. • Worldwide, 5.8 billion tons of goods were traded by sea in 2001. This accounts for over 80 percent of world trade by volume. • Over 318 billion gallons of petroleum products are shipped in vessels on U.S. waterways in a year. • Cruise ships calling at U.S. ports carry over 6 million passengers per year Source: MarAd

39. Port Security Measures July 1, 2004 • Security assessments and plans • 9500 vessels • 3500 facilities • Implementation of plans • increased identification checks • additional canine detection teams • expanded baggage and passenger screening • strategically placed perimeter fencing equipped with newly installed surveillance cameras Source: Secure Seas, Open Ports: Keeping our waters safe, secure and open for business, DHS, June 21, 2004

40. Source: Secure Seas, Open Ports: Keeping our waters safe, secure and open for business, DHS, June 21, 2004.

41. Layers of Maritime Security Source: Secure Seas, Open Ports: Keeping our waters safe, secure and open for business, DHS, June 21, 2004.

42. Coast Guard enforcing a security zone around a moored LNG tanker GMU School of law, The CIP Report, Issue 104, March 2011.

43. Safety and Security • Maritime Transportation Security Act of 2002 (MTSA) • Requires vessels and port facilities to conduct vulnerability assessments and develop security plans • Required possession of Transportation Worker Identification Credential (TWIC) • Safe Port Act of 2006 • Added requirements to MTSA to improve security of U.S. ports • Oversight must balance security and commerce needs

44. TSA Air Cargo Security Program • The 9/11 Act (2007) requires TSA to establish a system to ensure 100% screening of both domestic and international inbound cargo on passenger aircraft. • TSA has provided air carriers a path toward achieving 100% screening of international inbound cargo through risk-based analysis of shippers and shipments. • The National Cargo Security Program (NCSP) is an important component of this risk-based strategy. • Recognition of commensurate NCSP that will allow inbound air carriers departing from countries with programs commensurate to the U.S. to follow only the security requirements of host governments (NCSP Recognition). Gary Lupinacci, TSA’s Efforts to Ensure 100% Screening of Air Cargo on Passenger Aircraft, TSA/DHS, May 2012, http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf (accessed Feb 2013). 44

45. NCSP Recognition Process • Host Country provides security program to TSA • TSA reviews program • Site visit is planned for review by both parties • If program is deemed to be commensurate, TSA confers formal recognition of a country’s NCSP • Renewal of this recognition is at a pre-determined time interval Gary Lupinacci, TSA’s Efforts to Ensure 100% Screening of Air Cargo on Passenger Aircraft, TSA/DHS, May 2012, http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf (accessed Feb 2013). 45

46. Implementation of Air Cargo Screening • The 100 percent cargo screening rule has been in force for domestic passenger flights since 2010. • Enforcement of 100 percent cargo screening for inbound international passenger flights to the U.S. began in December 2012. • “Screening” does not necessarily mean “scanning.” • evaluate the contents, sender and destination of packages • do more intensive inspections on high-risk cargo • establish a secure chain of custody from the shipping facility to the aircraft • The key is to identify trusted shippers – and then focus on screening suspicious packages. • Achieving 100 percent screening of all-cargo aircraft remains a challenge. A Primer On Air Cargo Security, http://www.aviationpros.com/article/10771368/a-primer-on-air-cargo-security, Sept 2012 (accessed Feb 2013). 46

47. 2010 San Bruno Pipeline Explosion Photo by Thomas Hawk, Sept 19, 2010 (some rights reserved). http://www.flickr.com/photos/thomashawk/5006343716

48. 2010 San Bruno Pipeline Explosion • September 9, 2010, 6:11 p.m. • 30-inch steel natural gas pipeline • 2 mi west of San Francisco International Airport near Skyline Boulevard and San Bruno Avenue • 8 deaths, 6 missing, 60 injured • 37 homes destroyed • The pipe was a main transmission line that fed off to smaller distribution lines

50. US Pipeline Network