1. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 1 In the wake of the September 11 th attack and continuing terrorist threats, shippers, carriers, and marketers who offer, transport, or store hazardous materials have a greater responsibility for safeguarding personnel, facilities, cargo, and vehicles during the working with, and transporting of, hazardous materials. In this module you will learn to identify: 1.Regulatory requirements relating to hazmat security awareness training 2.Regulatory requirements for developing a security plan for hazardous materials 3.General considerations for security of the bulk plant and railcar site 3.6.6 Identifying Railcar Area Security Procedures

2. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 1 Identifying Regulatory Requirements Relating To Hazmat Security Awareness Training The transportation of hazardous material is regulated under Title 49 of the Code of Federal Regulations. As of March 25, 2003, the 49 CFR 172.704- Training Requirements were revised and now includes two new paragraphs relating to Security Training. They are Paragraphs (a)(4) and (5):

3. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 1 & 2 Identifying Regulatory Requirements Relating To Hazmat Security Awareness Training 49 CFR 172.704 Training Requirements : (a)(4)Security Awareness Training. No later than the dated of the first scheduled recurrent training after March 25, 2003, and in no case later than March 24, 2006, each hazmat employee must receive training that provides an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. This training must also include a component covering how to recognize and respond to possible security threats. After March 25, 2003, new hazmat employees must receive the security awareness training required by this paragraph within 90 days after employment. (a)(5)In-Depth Security Training. By December 22, 2003, each hazmat employee of a company or person required to have a security plan in accordance with subpart I of this part must be trained concerning the security plan and its implementation. Security training must include company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure.

4. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 1 & 2 Identifying Regulatory Requirements Relating To Hazmat Security Awareness Training 49 CFR 172.704 Training Requirements : OSHA, EPA, and Other Training. Training conducted by employers to comply with hazard communication programs required by the Occupational Safety And Health Administration of the Department of Labor (49 CFR 1910.120 or 1910.1200) or the Environmental Protection Agency (40 CFR 311. 1), or training conducted by employers to comply with security training programs required by other Federal or international agencies, may be used to satisfy the training requirements in paragraph (a) of this section to the extent that such training addresses the training components specified in paragraph (a) of this section.

5. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 2 Identify Regulatory Requirements for Developing a Security Plan for Hazardous Materials § 172.800 Purpose and applicability : Purpose Applicability : By September 25, 2003, each person who offers for transportation in commerce or transports in commerce one or more of the following hazardous materials must develop and adhere to a security plan for hazardous materials that conforms to the requirements of this subpart. A shipment of a quantity of hazardous materials in bulk packaging having a capacity equal to or greater than 13,248 L (3,500 gallons) for liquids or gases. A shipment in other than bulk packaging of 2,268 kg (5,000 pounds) gross weight or more of one class of hazardous materials for which placarding of a vehicle, railcar, or freight container is required for that class under the provisions of subpart F of the part Also included in 49 CFR 172, Subpart I is the requirement for the development of a hazardous material security plan.

6. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 3 Identify Regulatory Requirements for Developing a Security Plan for Hazardous Materials § 172.802 Components of a Security Plan. At a minimum, a security plan must include the following elements: Personnel Security Unauthorized Access En Route Security The security plan must be in writing and must be retained for as long as it remains in effect. Copies of the security plan, or portions thereof, must be available to the employees who are responsible for implementing it, consistent with personnel security clearance or background investigation restrictions and a demonstrated need to know. The security plan must be revised and updated as necessary to reflect changing circumstances. When the security plan is updated or revised, all copies of the plan must be maintained as of the date of the most recent revision.

7. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 3 Identify Regulatory Requirements for Developing a Security Plan for Hazardous Materials § 172.804 Relationship to other Federal requirements: To avoid unnecessary duplication of security requirements, security plans that conform to regulations, standards, protocols, or guidelines issued by other Federal agencies, international organizations, or industry organizations may be used to satisfy the requirements in this subpart, provided such security plans address the requirements specified in this subpart

8. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 4 Identifying General Considerations for Security of the Bulk Plant and Railcar Site Bulk Plant Facility Security Section 3.2.18 Internal Valves paragraphs 3.2.18.1 through 3.2.18.4 Section 3.2.19 Emergency Shutoff Valves paragraphs 3.2.19.1 through 3.2.19.9 Section 3.3.6 Protection Against Tampering for Section 3.3 and 3.9 Systems paragraphs 3.3.61 through 3.3.8 Section 3.11.4 Facility Piping Requirements sections 3.11.4.1 through 3.11.5.1 Paragraph 4.2.3.1 Employee Awareness

9. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 4 Identifying General Considerations for Security of the Bulk Plant and Railcar Site When an Orange Alert (indicating a “High” condition) is issued, the facility operator should: Allow only scheduled visitors and deliveries and verify the legitimacy of visiting customers; Advise employees to be more vigilant and report suspicious behavior; Control access to areas of concern within the facility In addition, when the plant is unattended (such as nights or weekends), the following precautions should be observed Lock plant gates. Close valves on all primary liquid and vapor lines. Lock all placarded vehicles with keys stored in a safe area and secured area.

10. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 5 Identifying General Considerations for Security of the Bulk Plant and Railcar Site When the Office of Homeland Security Issues a Red Alert (indicating a “Severe” condition), the facility operator should accomplish all items listed above, as well as : Advise drivers that delivery vehicles are to be returned to a pre-determined secure area at the end of their shift. Limit site access to one entrance. Increase facility surveillance. Inspect incoming transport vehicles prior to permitting entrance. Require drivers to check in with an authorized company representative at periodic intervals.

11. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 5 Identifying General Considerations for Security of the Bulk Plant and Railcar Site Cargo Tank Vehicle Security Industry supported recommendations for cargo tank drivers include the following: Be aware of their surroundings and situations, which are different than what they have encountered in the past. They should be advised to err on the side of conservatism and seek help from local law enforcement should they feel in danger. Keep all vehicle doors locked at all times. Always keep vehicles within site.

12. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 5 Identifying General Considerations for Security of the Bulk Plant and Railcar Site Cargo Tank Vehicle Security Industry supported recommendations for cargo tank drivers include the following: Where equipped, always carry remote shutdown activation devices even when not making a delivery. Never leave the truck unlocked while unattended. Do not stop to assist anyone unless they are personally known. If available, use a cell phone to call for help. Consider installing a security code device in bulk trucks and/or transports if these vehicles operate in major metropolitan areas.

13. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPage 5 Identifying General Considerations for Security of the Bulk Plant and Railcar Site A fundamental security measure for railcar operations is the efficient and timely performance of receiving, unloading, and turnaround release, so the railcar is on or alongside the bulk plant for the shortest time possible.

14. 3.6.6 Student Book © 2004 Propane Education & Research CouncilPages 6 & 7 Time to See If You Got the Key Points of This Module… Complete the Review on page 6. See if you are ready for the Certification Exam by checking off the performance criteria on page 7.