TSA Announces Security Recommendations for Highway Transport of Certain Sensitive Materials
On July 16, 2008, the Transportation Security Administration announced a set of security recommendations for the transportation of certain quantities of TIER 1 and TIER 2 Highway Security-Sensitive Materials (HSSM)1 by motor carriers. The voluntary guidelines were developed over a three-year period in close collaboration with government and private sector partners.
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According to TSA, TIER 1 and 2 HSSMs in certain quantities have the potential to cause significant fatalities and injuries or significant economic damage when released or detonated during a transportation security incident.
Action Items Cover General Security, Personnel Security, En-Route Security, Etc.
The security action items recommended by TSA are divided into the categories of (1) general security (2) personnel security, (3) unauthorized access, and (4) en-route security. Specifically, TSA recommends the following (partial list):
General Security
Awareness of industry practices. Employers should become familiar with security practices recommended by industry groups and trade associations such as the American Chemistry Council's (ACC) Responsible Care Program, the Chlorine Institute's Security Management Plan, the International Cargo Security Council and other entities offering similar security guidance.
Inventory control procedures. Employers should implement procedures to maintain accountability for their containers, cylinders, and vehicles at all times while in transport throughout the supply chain. Inventory control information should include: pertinent shipping information; material location; tracking processes; and verification procedures.
Security of critical information. Employers should implement policies to protect critical information, addressing current methods of communication between shippers, carriers, third-party logistic companies, and receivers. Information flow should be reduced to that which is essential to accomplish the task of transporting the hazardous material shipments. Communications and information systems (telecommunications, computer systems, printed materials, verbal communications and all networks on which they operate) should be protected from unauthorized access.
Personnel Security
Possession of valid CDL/HME. Employers should verify that drivers have a valid commercial drivers license (CDL) with a Hazardous Materials Endorsement (HME), as this means drivers will have undergone a Security Threat Assessment conductedby the TSA under 49 CFR Part 1572.
Background checks for other employees. During the hiring process, an employer in the highway-related hazmat supply chain should conduct a background check for employees and contractors with unescorted access to motor vehicles (in transport), the motor carrier facility, or information critical to the hazmat transportation.
Security training for employees. Employers may wish to establish security awareness training programs that at a minimum address methods to: restrict access to sensitive information on HSSM such as shipping papers, dates of shipment and arrival, destination and routing information; recognize suspicious activities, etc.
Unauthorized Access
Access control system for drivers. Employers should implement an access control system that includes issuing company photo IDs or other visible forms of company identification to all drivers to be used to gain access to company designated restricted areas and also for shippers, consignees and others to verify the drivers' current employment status.
Access control system for facilities incidental to transport. Employers should implement a similar access control system for all employees, vendors, contractors, and visitors who require unescorted access to restricted areas, including plants, data centers and IT systems, loading and unloading facilities, storage facilities, etc.
En-route Security
Cargo security program. Employers should ensure that all cargo containers (including but not limited to trailers, tankers, straight trucks, security cages, and flatbeds) are secured when in use but unattended through use of a primary and secondary securement system.
High alert level protocols. Employers should establish policies governing operations during periods of increased threat conditions under the Homeland Security Advisory System (for example when the Department of Homeland Security (DHS) Threat Condition is raised from Orange to Red).
Shipment planning/coordination. (TIER 1 only) The shipper (consignor), motor carrier and receiver (consignee) should conduct shipment pre-planning to ensure shipments are not released to the motor carrier until they can be transported to destination with the least public exposure and minimal delay in transit. When shipments are in transit, the motor carrier should coordinate with consignee to confirm the estimated time of arrival. Upon receipt, consignees should notify the shipper that the shipment has arrived on schedule and materials are accounted for.
Preplanning routes. (TIER 1 only) Employers should ensure preplanning of primary and alternate routes. This preplanning should seek to avoid or minimize proximity to highly populated urban areas or critical infrastructure such as bridges, dams, and tunnels.
Trips exceeding driving time under HOS regulations. (TIER 1 only) Employers should examine security in light of hours of service (HOS) available and take steps to mitigate the vulnerabilities associated with extended rest stops for driver relief. Examples include methods such as constant vehicle attendance or visual observation with the vehicle, driver teams, or vetted companions.
Tractor/trailer tracking systems. (TIER 1 only) Employers should have the ability of implementing methods of tracking the tractor and trailer throughout the intended route with satellite and/or land-based wireless GPS communications systems.
TSA Seeks Feedback, Will Consider Action Items for Development as Regulations
TSA will build on these recommendations by analyzing the effectiveness of the security action items and feedback the Highway and Motor Carrier Division receives from industry. TSA will consider the security action items for development as regulations.
Questions and comments from industry may be sent to the TSA Highway and Motor Carrier Division at highwaysecurity@dhs.gov.
1Includes certain explosives; flammable gases, liquids, and solids; spontaneously combustible material; dangerous when wet material; poisonous materials; etc.
TSA security recommendation information, including links to Appendix A (description of the voluntary security action items), Attachment I to Appendix A (guidance for background checks), and Appendix B (list of Tier 1 and Tier 2 HSSMs) available at http://www.tsa.gov/what_we_do/tsnm/highway/hssm_sai.shtm
TSA press release (dated 07/16/08) available at http://www.tsa.gov/press/releases/2008/0716.shtm