Airgas-SAFECOR — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportatior Washington, D.C. 20590 400 Seventh Street, S.W. piperials sately Administration AUG 10 2006 Mr. John Anderson P.O. Box 20067 Airgas-SAFECOR Ref. No. C6-0170 Cheyenne, WY 82003 Dear Mr. Anderson: This is in response to your letter requesting clarification of the security plan requirements you ask whether the HMR require a "site specific" security plan. You state that you under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, cannot find the term in the HMR, but understand that it is a requirement. You have been asked by auditors to produce a site specific security plan and documentation of training on the plan, and you request HMR cite references for these requirements. The requirement to develop and implement a security plan applies to persons who offer for transportation or transport the hazardous materials specified in § 172.800 of the risks for shipments of the listed hazardous materials and appropriate measures to address HMR. Each security plan must include an assessment of possible transportation security unauthorized access, and en route security, as provided in § 172.802. those risks. At a minimum, each security plan must address personnel security, The HMR set forth general requirements for a security plan's components rather than a standard providing shippers and carriers with the flexibility necessary to develop security prescriptive list of specific items that must be included. The HMR set a performance plans addressing their individual circumstances and operational environment. Accordingly, each security plan will differ because it will be based on a shipper's or a carrier's individualized assessment of the security risks associated with the specific hazardous materials it ships or transports and its unique circumstances and operational environment. For companies with more than one facility where a hazardous material listed in § 172.800 is offered for transportation in commerce, each facility should have a security plan tailored to the specific hazardous materials handled at the facility, the physical characteristics of the facility, and the operational procedures in place at the facility. A facility may utilize a security plan template developed by its corporate leadership for all facilities owned by the corporation or an industry association or other 172.800 060170#

Page 2third-party with security planning expertise. However, each facility must adapt such templates to ensure its security plan addresses any security vulnerabilities unique to that facility. To assist industry in complying with the security plan requirements, PHMSA developed a identify areas in the transportation process where security procedures should be enhanced security plan template to illustrate how risk management methodology could be used to within the context of an overall risk management strategy. The security template is posted in the docket and on the PHMSA website at http://hazmat.dot.gov/rmsef.htm. With respect to documented training on the security plan, § 172.704(a)(4) and (a)(5) requires a record of the training. require security awareness and in-depth security training, respectively, and § 172.704(d) I hope this information is helpful. If you need further assistance, please contact this office. Sincerely, Holle Kilok Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention#

Page 3Page 1 of 1 Drakeford, Carolyn <PHMSA> From: Gorsky, Susan <PHMSA> Sent: VInture Friday, July 21, 2006 7:12 AM To: Drakeford, Carolyn <PHMSA> 3172.800 Subject: FW: Question regarding security plans Security Plans Please enter this into the interp data base. 06 - 0!70 Susan Sent: Thursday, July 20, 2006 4:13 PM From: John Anderson (SAFECOR) [mailto:John.Anderson@Airgas.com] To: Heneghan, John <PHMSA> Subject: Question regarding security plans Good afternoon, thought I read in the security section (of 49 CFR) that a site specific plan was required. And during recent I would like to ask a question about security plans. Is the security plan required to be site specific? In the past I PHMSA audits we have been asked to produce a site specific plan and documented training on the plan. t a meetina todav at the CGA it was stated that the phrase site specific is not found in 49 CFR. I reviewed 4 FR 172.700 throuch 172.800 (Suboan H and I andi did not tind a reterence Does PHMSA require a site specific plan and if so, what is the CFR reference? Thank you for your response. John Anderson Airgas-SAFECOR Cheyenne, WY 82003 P. O. Box 20067 Fax 1-307-778-7497 Phone 1-307-778-8809 john.anderson@airgas.com 7/21/2006#