Do you need a Security Plan?
Posted on August 15, 2007
Filed Under GENERAL, GETTING AUDITED
If you are a carrier or shipper of placardable amounts of hazardous materials, you need, among numerous other requirements, a security plan. This is a written document where you outline how risky you believe your HazMat operation is, and the measures you have in place to prevent terrorists from stealing or sabotaging your HazMat. The security plan regulations came about, naturally, following the 9-11 attacks. DOT loves issuing security plan fines. You might think DOT would take a cooperative approach, and assist industry in developing these plans, and otherwise help them without punitive fines. Well, if you think that, you’ve thought wrong. Security plan fines are big and plentiful. $10,000 or $20,000 is not unusual.
A shipper or carrier can not only be fined for not having a plan, they can be fined if their plan is not comprehensive enough in the judgement of the DOT inspector. You can even be fined if you have a plan, but are not following your own plan. For example, if you have a plan which says that all visitors will be required to sign in and wear name tags, and no one asks the DOT inspector to sign in or wear a name tag….. you could be fined. Sound ridiculous? It has happened. If you transport or ship HazMat via trucks, you should inquire as to the regulations, and make sure you are in compliance with 49 CFR 100-199.
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Eric Arnold is a Former Enforcement Agent with the Federal Motor Carrier Safety Administration, and a leading expert on USDOT compliance for small businesses. Do you have a question for Eric Arnold? Email him at eric@arnoldsafety.com.
Arnold Safety simplifies D.O.T. Compliance for commercial vehicle operators. Get Eric Arnold’s USDOT Compliance Guide, DVD, & Regulations at ArnoldSafety.Com.
Learn more about Arnold Safety compliance consulting services at ArnoldSafety.Com.
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