1. TOOLKIT FOR HAZARDOUS MATERIALS TRANSPORTATION EDUCATION 1

2. Module 7: Security of Hazmat Transportation Shipments 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

3. Learning Outcomes At the end of this module students will be able to: 1.Explain the threats posed against hazmat during all phases of transport. 2.Locate the key regulations governing the security of dangerous goods shipments. 3.Describe the general principles of ensuring hazmat shipment security. 4.Illustrate specific examples of security measures for each mode of transportation. 3

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) 4

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

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 6

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. 7

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). 8

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 9

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

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 11

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

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

14. Hazmat Facilities 1.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. 2.Secure all entry and exit points of your facility. 3.Develop and maintain an employee ID program. 4.Erect and maintain security fencing around the perimeter of your property. 5.Keep entry doors and entrances secure and locked if fire codes permit. 6.Have visitors sign-in and show ID and wear a visitor pass. Maintain the visitor roster for 12 months. 14 Source: Transportation Security Administration

15. Hazmat Shippers 1.During cargo loading, monitor loading and to the extent operations allow, provide carrier with a safe and secure location for loading. 2.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. 3.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. 4.Remind the carrier about established stopping and parking procedures, and caution them not to make any unscheduled stops. 5.Be aware of possible “ruses.” If you are unsure if a police officer is real, call 911 and ask. 15 Source: Transportation Security Administration

16. Hazmat Drivers 1.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. 2.Have a communication device with you at all times. 3.Do not make any unscheduled stops. 4.Report any suspicious activities or emergencies to law enforcement authorities. 5.Report any suspicious activities to dispatch. 6.Remain particularly observant for suspicious activities in and around refueling locations, intermodal terminals, bridges, and tunnels. 16 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 17

18. FOT Framework 18 Source: FMCSA

19. Selection of Technologies for Operational Scenarios 19 Source: FMCSA

20. 20 Source: FMCSA

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

22. Biometric Identification 22 Source: FMCSA

23. Remote Cargo Locks 23 Source: FMCSA

24. Electronic Cargo Seals 24 Smart Seal Tag Source: FMCSA

25. Geofencing 25 Source: FMCSA

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

27. Some FOT Results 27 Source: FMCSA

28. Summary of FOT Findings 28 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. 29

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 30

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. 31

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. 32

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. 33

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. 34

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). 35

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 36

37. 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 38 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 39

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

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

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

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 43

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). 44 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).http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf

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 45 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).http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf

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. 46 A Primer On Air Cargo Security, http://www.aviationpros.com/article/10771368/a-primer-on-air- cargo-security, Sept 2012 (accessed Feb 2013).http://www.aviationpros.com/article/10771368/a-primer-on-air- cargo-security

47. 2010 San Bruno Pipeline Explosion 47 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 48

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50. 50 US Pipeline Network

51. Pipeline Releases Accidental pipeline releases result from a variety of causes – outside force (e.g., third-party excavation) – corrosion – mechanical failure – control system failure – operator error – natural forces, such as floods and earthquakes According to the DOT, of 183 gas pipeline accidents reported in 2002, outside forces were by far the leading cause, accounting for 46% of reported failures. Outside forces was also the leading cause of the 140 oil pipeline accidents in 2002, responsible for 32% of failures. Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities and Current Policy Issues, Congressional Research Service, Feb 2004. 51

52. Security Aspects of Pipeline Releases A single pipeline incident can be catastrophic and therefore are attractive terrorist targets. However, accidental releases happen much more frequently than intentional ones. Pipeline releases generate substantial scrutiny of pipeline regulation and increased state and community activism related to pipeline safety and security. Fortunately, the pipeline industry has extensive experience responding to releases and generally does so relatively quickly. 52 Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities and Current Policy Issues, Congressional Research Service, Feb 2004.

53. Pipeline Security: Vulnerability Like any physical system, pipelines are vulnerable to vandalism and terrorist attack. – The physical plant of these facilities may be damaged with explosives or by other mechanical means, disrupting flows and causing a release of pipeline contents. – Computer control systems may be “cyber-attacked” – Both physical and cyber attack may happen at the same time Some pipelines may also be indirectly disrupted by other types of terror strikes, such as attacks on regional electricity grids or telecommunications networks, which could in turn affect dependent pipeline control and safety systems. Since pipelines supply fuel for vehicles, power plants, aircraft, heating, military bases and other uses, serious disruption of a pipeline network poses additional “downstream” risks. Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities and Current Policy Issues, Congressional Research Service, Feb 2004. 53

54. Pipeline Security: Attack Examples Some attacks and threats against pipelines and related infrastructure have occurred in the United States. In 1997, Texas police prevented the bombing of natural gas storage tanks at a processing plant by Ku Klux Klan members seeking to create a diversion for a robbery (to finance other terrorist actions). In 1999, Vancouver police arrested a man planning to blow up the trans-Alaska pipeline for personal profit in oil futures. He was found with high explosives and timers for 14 bombs. In 2001, a vandal’s attack with a high-powered rifle, also on the trans- Alaska pipeline, forced a two-day shutdown and caused extensive economic and ecological damage. Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities and Current Policy Issues, Congressional Research Service, Feb 2004. 54

55. Pipeline Security Activities and Policies of Federal Agencies The Transportation Security Administration (TSA), within the Department of Homeland Security (DHS), is the lead federal agency for security in all modes of transportation — including pipelines. TSA expects pipeline operators to maintain security plans based on security guidance initially circulated in 2002. PHMSA is the lead federal regulator of pipeline safety and security. TSA and PHMSA currently cooperate on security inspections, but many in industry are still concerned about the possibility of redundant, conflicting regulatory regimes. Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities and Current Policy Issues, Congressional Research Service, Feb 2004. 55

56. Pipeline Security Tradeoffs Various industry representatives state that they need clear and stable definitions of pipeline asset criticality, so they will know exactly what assets to protect, and how well to protect them. – Otherwise, the pipeline industry risks hardening too many facilities, hardening the wrong facilities, or both. – Either outcome would increase ultimate costs to consumers without commensurate security benefits, and could potentially divert scarce security resources from better uses within or outside the pipeline industry (e.g., securing electric power stations). Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities and Current Policy Issues, Congressional Research Service, Feb 2004. 56

57. Customs‐Trade Partnership Against Terrorism (C‐TPAT) Sponsored by U.S. Customs and Border Protection, DHS A voluntary government‐business initiative to build cooperative relationships that strengthen and improve overall international supply chain and U.S. border security. Includes more than 10,000 certified partners that span the gamut of the trade community. The partnership establishes clear supply chain security criteria for members to meet and in return provides incentives and benefits like expedited processing. – companies sign an agreement to work with CBP to protect the supply chain, identify security gaps, and implement specific security measures and best practices – partners provide CBP with a security profile outlining the specific security measures the company has in place An emerging focus: Mutual Recognition Arrangements 57 Source: U.S. Customs and Border Protection, DHS.

58. Key Takeaways Hazmat shipments and facilities are a security concern because of their potential to be used as means of attacking other targets. Measures that improve cargo security in general are equally applicable to hazmat shipment security. The most effective security enhancement procedures are multi-layered systems that address each aspect of vulnerability. En route security is challenging due to the many uncontrolled factors involved. Industry and government are cooperating to enhance hazmat security. 58

59. Student Exercises 1.Select one of the technologies tested in the FMCSA hazmat security field operational test and discuss its application costs and benefits. 2.For three security enhancing technologies assigned by the instructor, determine the impact of each on the transportation organization’s efficiency and safety. 59

60. Resources for Support and Additional Learning Ritter et al, Securing Global Transportation Networks, McGraw-Hill, 2007. Recommendations for Bridge and Tunnel Security, FHWA and AASHTO, September 2003 (http://www.fhwa.dot.gov/bridge/security/brptoc.htm).http://www.fhwa.dot.gov/bridge/security/brptoc.htm FEMA 426, Risk Management Series, Reference Manual to Mitigate Potential Terrorist Attacks Against Buildings, Federal Emergency Management Agency, Washington, DC, December 2003. Federal Motor Carrier Safety Administration, Hazardous Material Transportation Safety and Security Field Operational Test (FOT) Final Report – Deployment Team, FHWA-OP-03-XXXX, USDOT, Washington, DC, August 31, 2004. http://www.fmcsa.dot.gov/documents/hazmat/fot/HMFOT-Final-Report.pdf http://www.fmcsa.dot.gov/documents/hazmat/fot/HMFOT-Final-Report.pdf Parfomak, Paul W., Pipeline Security: An Overview of Federal Activities and Current Policy Issues, RL31990, Congressional Research Service, Washington, DC, Feb 2004. http://www.fas.org/sgp/crs/RL31990.pdf. http://www.fas.org/sgp/crs/RL31990.pdf DeBlasio, Allan J., et al., Effects of Catastrophic Events on Transportation System Management and Operations: Cross Cutting Study, U.S. Department of Transportation, Volpe National Transportation Systems Center, Cambridge, MA, January 2003. 60