SOP 4



SOP 4.14: DOT Security Plan

Contents

1. Introduction 1

2. Regulatory and contractual requirements 1

3. Designating and training staff 1

4. Security equipment 2

5. Security specifications and risk management 2

Attachment A: U.S. DOT Security plan training documentation 8

1. Introduction

Department of Transportation (DOT) Security Plans outline specific actions to ensure Household Hazardous Waste (HHW) Facility operations are conducted in a safe and secure manner and to prevent access by unauthorized persons. Since this Facility offers hazardous materials (hazmat) for transport, DOT requires review and implementation of any necessary adjustments to improve hazmat security.

2. Regulatory and contractual requirements

Secure storage of hazardous waste (HW) is governed by the requirements established in the HHW Program and state agency contract, Minn. Stat. § 299F.01; Minn. Rules pt. 7045.0310, 7045.7510, 7045.7562, 7045.0566, and 7045.0626; OSHA 29 CFR 910.120, 1910.141, 1910.151, 1910.157; DOT hazmat Security Plan information (, what_we_do/layers/hazmat/faq.shtm); Minnesota Uniform Fire Code 7045.0566 and local building codes; Environment Protection Agency (EPA) 49 CFR 172.704, 172.800, 172.802, and 172.804.

3. Designating and training staff

3.1 Any government agency that transports or offers for transport a placardable type or quantity of HW shall prepare, adhere to, and train each staff on this site-specific DOT security plan; see Attachment A of this SOP. The designated staff member responsible for ensuring DOT Security plan compliance is the Facility Manager. This person shall ensure:

• the plan is reviewed and updated on an annual basis.

• new staff receive pre-employment screening.

• disciplinary actions are taken when a staff member fails to follow security policy and procedures.

• staff accountability for authorized Facility keys.

• security threats are identified and prioritized so available resources can be allocated effectively to reduce or eliminate all risks.

• staff diligently assist in implementing the DOT Security Plan to continuously improve the Program’s security efforts (e.g., identifying areas or methods requiring improvement).

• partnership with all parties involved (e.g., other staff, customers, contractors, regulatory agencies) in securing the HW management and transportation chain.

3.2 Facility staff managing HW shall be able to demonstrate successful completion of DOT security training (or obtain equivalent training), see SOP 1.3 DOT. This training provides an understanding of precautions and hazmat management and transportation security methods, including:

• implementation of this Program’s DOT security plan and the organizational structure outline.

• emergency evacuation procedures.

• safety and security actions to protect Facility property and the hazardous material stored on site.

• specific preparedness, site diagrams, and security measures to prevent a contingency event from occurring.

• designating Facility staff for incident notification to regulatory agencies, law enforcement, and public service authorities.

• how to recognize and respond to possible security threats.

• security policy details, including specific objectives and procedures.

• response responsibilities and actions in the event of a security breach.

• awareness of security risks MRW transportation and storage.

• how to recognize and respond to security threats using a specified procedure.

3.3 The Program DOT Security Plan shall be made available on a need-to-know basis. Staff shall receive in-depth instruction when circumstances dictate.

4. Security equipment

4.1 Staff shall use appropriate Facility security measures at all times. The level of security will vary based on the Facility itself and the surrounding environment. Outside Facility security enhancements may include:

• adequate lighting, illuminated from dusk to dawn.

• surveillance, recording equipment, intrusion alarms, motion detectors.

• fence and gates to restrict access.

• emergency notification contact number posting.

• signage clearly stating that Facility access is restricted to authorized staff only.

4.2 Security measures shall minimize the possibility for unauthorized entry. Staff shall ensure security precautions in all Facility areas (e.g., product exchange; waste processing, and storage areas; air, water, gas, and utility equipment). Security items shall be incorporated into the Facility’s interior design, be maintained in good working condition, and may include:

• a communication system or panic button(s)

• controlled entry

• 24-hour surveillance system

5. Security specifications and risk management

5.1 Facility control measures. This Facility shall be maintained and operated in a manner that provides adequate security, which may include:

5.1.1 a security walk-through performed each day the Facility is open, including inspecting recess or alcove areas, noting anything suspicious, and immediately reporting questionable activity to law enforcement.

5.1.2 24-hour contact information is listed in the HW Facility Contingency Plan and identifies back-up staff and other agencies to be notified dependent upon the type of incident; see SOP 2.10 HW Contingency Plan.

5.1.3 Facility flow, floor, and schematic plans are maintained and kept in secure locations. Such plans are in the direct control of the designated staff responsible for ensuring DOT security plan compliance and shall only be made available to local, state, or federal agencies.

5.1.4 Unmarked or unidentifiable containers received shall be treated as suspicious and immediately reported. Facility staff shall become familiar and recognize HW container markings, symbols, and designations.

5.2 Shipping waste control measures

5.2.1 It is essential that HW containers are properly identified and accounted for at all times. Each container offered or transported shall be marked and/or labeled in accordance with DOT regulations (information that clearly identifies the shipper of record).

5.2.2 DOT requires documentation identifying the hazardous material being transported (e.g., shipping paper, manifest, lab-pack sheet). Additionally, transactions between shippers, transporters, and destination facilities shall be clearly documented as a chain-of-custody transfer. Manifests shall be signed by the generator and receiving party prior to relinquishing the shipment.

5.2.3 When supervising a hazmat shipment, staff shall determine the piece count of the shipment and verify that with the number of containers documented on the manifest. Any discrepancy or other suspicious activity shall be reported to the designated staff responsible for ensuring DOT Security compliance.

5.2.4 Preventing unauthorized individuals from accessing containers of hazmat is critical to maintaining security. Only specifically authorized Program staff shall be provided access to:

• government-owned transport vehicle(s) loaded with hazmat.

• areas where containers holding hazmat are stored.

5.3 Driver en-route control measures

5.3.1 Regardless of the type or quantity of hazmat transported or offered by this Program, security for the shipment shall be maintained at all times. To prevent unauthorized access, the driver shall ensure the Program vehicle:

• doors remain locked when unattended.

• remains within sight during cold start-up or for extended idling times.

• is locked with access to a second key (to allow for reentry if temporarily left unattended).

5.3.2 Staff shall be responsible for providing appropriately sized locks or seals for Program vehicles. The cargo portion of the vehicle shall be locked or sealed from the time the driver receives the shipment until delivered to the destination site. If it is necessary to load or unload materials from the vehicle prior to reaching the final destination, it is the driver’s responsibility to relock or apply a new vehicle lock or seal.

5.3.3 While transporting hazmat for mobile event collections, staff shall take appropriate action to prevent tampering with the shipment. This may include securing cargo areas with tamper-proof locks or seals. Locks or seals are not needed when the vehicle is:

• not transporting hazmat.

• parked at a secure Facility.

• attended by Facility staff.

5.2.4 Program drivers are responsible for assuring the property and waste is secure during transport. Drivers shall strictly adhere to this Program’s personnel security policy, which may include:

• not allowing unauthorized persons to ride in or operate Program vehicles.

• be alert and aware of vehicle surroundings (e.g., suspicious people or activities, other vehicles following).

• satisfying all driver qualification requirements as outlined in the Federal Motor Carrier Safety Regulations.

• complying with all applicable federal and state routing requirements (e.g., use designated hazmat routes; avoid tunnels, bridges, and heavily populated areas).

• carrying proper proof of personal identification (e.g., state-issued photo driver’s license appropriate to the vehicle driven, medical certification card).

• adhering to all site-specific security rules while performing work at a non-Program-owned or operated work-site.

• delivering shipments without delay and proceeding directly to the delivery point without intermediate stops.

• limiting stops to only obtain rest, meals, perform vehicle inspection and maintenance activities, or complete scheduled pick-ups.

• not stopping or exiting the vehicle at anyone’s request (other than law enforcement).

• immediately reporting injury or spill incidents to emergency responders and to the designated Facility staff responsible for ensuring DOT Security compliance.

5.3.5 If required to park a Program vehicle overnight, the driver shall obtain prior approval from the designated staff responsible for ensuring DOT Security compliance. While parked, the Program vehicle shall be locked, remain connected to the truck trailer (if applicable), and be parked in a location that is:

• more than five feet from the traveled portion of a street or highway.

• legally acceptable and in compliance with all applicable requirements specific to the materials being transported.

• well-lit.

• where other vehicles are present.

• secured.

• not near the driver’s home, private residences, tunnels, bridges, or places where people congregate.

5.3.6 Drivers are required to maintain communications with Facility staff daily. This includes notifying the designated staff responsible for ensuring DOT Security compliance of any unusual en route delays, piece count discrepancies, or other suspicious incidents. If a driver fails to check in when required, the incident shall be assumed suspicious and be immediately reported and/or investigated.

5.3.7 Staff identification (e.g., program-issued photo badge) shall be kept on person while at work. Staff-issued identification items shall be returned upon employment termination.

5.3.8 Drivers shall use caution to not discuss shipment details or load-related information (e.g., load content, delivery schedules, routing) with any person unrelated to the shipment. Program drivers shall be provided communication devices for local emergency and/or Facility staff contact, which may include:

• cellular telephone

• CB radio

• GPS system with two-way communication

5.4 Employer responsibility

5.4.1 Staff possessing a commercial driver’s license with a hazardous material endorsement shall undergo further security background checks by the Department of Justice in conjunction with license issuance or renewal. Only staff with a valid commercial driver’s license, proper endorsements, and a complete driver qualification file shall be authorized to operate a Program vehicle. A driver report shall divulge information regarding his or her:

• criminal history (if convicted of a disqualifying criminal offense).

• education background.

• social security number.

• citizenship status (shall be a U.S. citizen or a lawful permanent U.S. resident).

• general reputation, character, or personal characteristics.

• motor vehicle driving record (disqualified for improper transport of HM and requires mandatory annual driving record reviews).

• previous supervisor contact (suspicious if no longer currently working with the applicant, if there are no names of direct supervisors, if previous employers are noted as “being out of business,” or if the reasons for terminating employment are questionable).

• previous history shows:

1. gaps in employment

2. frequent job shifts

3. excess residence changes

4. mental instability (adjudicated as mentally defective by a court, board, or other lawful authority or previously committed to a mental institution or if person exhibits traits which may endanger the health or welfare of others).

5.5 Use of contracted HW transportation services

5.5.1 This Program requires hazmat transporters to have a documented security plan and to adhere to the security measures as described in this SOP. These additional security measures do not apply to contractors hired by this HHW Program for waste shipments (e.g., latex paint, universal) that pose a low security risk. Policy exceptions shall be pre-approved by designated staff responsible for ensuring DOT Security plan compliance.

5.5.2 Contracted HW transporters are required to secure the cargo portion of their vehicles while transporting this Program’s hazmat. When relinquishing a shipment to a contracted HW transporter, the designated staff responsible for ensuring DOT security plan compliance shall be present to verify the vehicle is affixed with an appropriate tamper-proof security device. Seals shall be provided if the contracted driver is unable to produce a locking device or trailer seal. This Program requires HW shipments remain sealed/locked while in transport.

5.5.3 Prior to offering a shipment to an HW-contracted disposal company, Program staff shall verify the identity of the contracted driver by reviewing his or her commercial driver’s license (CDL). Program staff shall not release any HW shipment if there is any concern about the driver’s identity or license validity. Facility staff shall ensure:

• the CDL has not expired.

• the CDL includes all vehicle and hazmat endorsements necessary to deliver the shipment in compliance with federal regulations.

• the contracted driver provides proof of medical examiner’s release to operate a commercial motor vehicle and all required documents are signed by a medical examiner.

• the dates printed on credentials (certificate or wallet card) have not expired.

5.6 General security measures

5.6.1 Contractors may be left unattended provided they register/notify Facility staff of their presence each day and display appropriate identification. Facility staff shall maintain and enforce a restricted Facility visitation policy, including ensuring unauthorized persons:

1. register.

2. are prohibited from accessing restricted areas unless accompanied.

3. are only allowed to enter the Facility when necessary and at designated entrances.

5.6.2 It is recommended Facility gates, fences, and doors:

• are locked at all times when staff is not present.

• have controlled entry.

• are six foot high, chain linked, and completely surround the Facility.

5.6.3 Hazmat storage areas shall be locked when Program staff is not on-site. Only the following areas are acceptable for hazmat storage while at a satellite Facility or collection event:

• inside a locked vehicle.

• within a locked building.

• inside a secure fence.

5.6.4 Staff shall be alert for suspicious activities, such as soil excavation on Facility property. Immediately verify if operation is authorized.

5.6.5 Staff shall implement a master and sub key system under the care and control of the designated staff responsible for ensuring DOT Security plan compliance. It is recommended Facility keys are:

• always accounted for.

• marked with the words “do not duplicate.”

• provided to emergency response teams.

• changed or rotated on a quarterly basis (with accompanying padlock).

5.6.6 This Facility shall be open to the general public during its posted hours of operation. Designated Facility areas that are not available to the general public shall be posted “authorized staff only” and no public admittance shall be permitted in those areas (unless pre-arranged with Facility staff). Any persons (excluding Facility or Emergency Response staff) who are on the premises after public hours shall be considered trespassing and prosecuted accordingly.

5.7 Emergency notification. Facility staff have responsibility to observe and report any suspicious activity (e.g., known thefts involving hazmat, missing containers, actions that threaten safety or security to appropriate law enforcement and/or regulatory agencies). All threats shall be treated as “real” and adequately investigated and reported. This Program staff shall periodically assess the effectiveness of the Facility’s DOT Security Program, including:

• conduct monthly safety inspections incorporating security checks into the program.

• assess the security vulnerabilities at each work site.

• develop and implement specific security measures in response to identified vulnerabilities.

• educate staff about the importance of security.

• implement and ensure policy compliance.

5.8 National security threats. The U.S. Department of Homeland Security has developed the Homeland Security Advisory System for notifying the public of the risk of a terrorist attack. The designated staff responsible for ensuring DOT security plan compliance shall monitor threat conditions, other government-issued security advisories, and notify others accordingly.

Attachment A

U.S. DOT Security Plan Training Documentation

This Security Plan shall be retained as long as it remains in effect. This plan must be revised and updated to reflect changing circumstances. Copies shall be available to Facility staff responsible for implementing the plan.

Hazardous Waste Facility _________________________________________________________

Located at _____________________________________________________________________

Provided U.S. DOT Security Awareness training reflective of the following:

| |√ |This training provided awareness of security risks associated with hazmat |

| | |management and transport. |

| |√ |This training provided awareness of methods designed to enhance hazmat security.|

| |√ |This training provided awareness so I am able to recognize security threats. |

| |√ |This training provided awareness so I am able to respond to security threats. |

| |√ |This training was provided within 90 days of employment and/or was offered as |

| | |part of my DOT refresher, which is required 1 time every 3 years. |

|(Employee initials | | |

|agreement of above | | |

|statements) | | |

|Signature of HHW Program Staff: _____________________________ Date__________ |

|Printed name: _______________________________________ |

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