{"operation":"document","citation":"06-0170","title":"Airgas-SAFECOR — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-08-10","effective_on":null,"summary":"06-0170 response to Airgas-SAFECOR concerning 172.800.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0170.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0170.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0170","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060170.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportatior\nWashington, D.C. 20590\n400 Seventh Street, S.W.\npiperials sately Administration\nAUG 10 2006\nMr. John Anderson\nP.O. Box 20067\nAirgas-SAFECOR\nRef. No. C6-0170\nCheyenne, WY 82003\nDear Mr. Anderson:\nThis is in response to your letter requesting clarification of the security plan requirements\nyou ask whether the HMR require a \"site specific\" security plan. You state that you\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically,\ncannot find the term in the HMR, but understand that it is a requirement. You have been\nasked by auditors to produce a site specific security plan and documentation of training\non the plan, and you request HMR cite references for these requirements.\nThe requirement to develop and implement a security plan applies to persons who offer\nfor transportation or transport the hazardous materials specified in § 172.800 of the\nrisks for shipments of the listed hazardous materials and appropriate measures to address\nHMR. Each security plan must include an assessment of possible transportation security\nunauthorized access, and en route security, as provided in § 172.802.\nthose risks. At a minimum, each security plan must address personnel security,\nThe HMR set forth general requirements for a security plan's components rather than a\nstandard providing shippers and carriers with the flexibility necessary to develop security\nprescriptive list of specific items that must be included. The HMR set a performance\nplans addressing their individual circumstances and operational environment.\nAccordingly, each security plan will differ because it will be based on a shipper's or a\ncarrier's individualized assessment of the security risks associated with the specific\nhazardous materials it ships or transports and its unique circumstances and operational\nenvironment. For companies with more than one facility where a hazardous material\nlisted in § 172.800 is offered for transportation in commerce, each facility should have a\nsecurity plan tailored to the specific hazardous materials handled at the facility, the\nphysical characteristics of the facility, and the operational procedures in place at the\nfacility. A facility may utilize a security plan template developed by its corporate\nleadership for all facilities owned by the corporation or an industry association or other\n172.800\n060170\n\n<<<PAGE 2>>>\n\nthird-party with security planning expertise. However, each facility must adapt such\ntemplates to ensure its security plan addresses any security vulnerabilities unique to that\nfacility.\nTo assist industry in complying with the security plan requirements, PHMSA developed a\nidentify areas in the transportation process where security procedures should be enhanced\nsecurity plan template to illustrate how risk management methodology could be used to\nwithin the context of an overall risk management strategy. The security template is\nposted in the docket and on the PHMSA website at http://hazmat.dot.gov/rmsef.htm.\nWith respect to documented training on the security plan, § 172.704(a)(4) and (a)(5)\nrequires a record of the training.\nrequire security awareness and in-depth security training, respectively, and § 172.704(d)\nI hope this information is helpful. If you need further assistance, please contact this\noffice.\nSincerely,\nHolle Kilok\nHattie L. Mitchell\nOffice of Hazardous Materials Standards\nChief, Regulatory Review and Reinvention\n\n<<<PAGE 3>>>\n\nPage 1 of 1\nDrakeford, Carolyn <PHMSA>\nFrom: Gorsky, Susan <PHMSA>\nSent:\nVInture\nFriday, July 21, 2006 7:12 AM\nTo:\nDrakeford, Carolyn <PHMSA>\n3172.800\nSubject: FW: Question regarding security plans\nSecurity Plans\nPlease enter this into the interp data base.\n06 - 0!70\nSusan\nSent: Thursday, July 20, 2006 4:13 PM\nFrom: John Anderson (SAFECOR) [mailto:John.Anderson@Airgas.com]\nTo: Heneghan, John <PHMSA>\nSubject: Question regarding security plans\nGood afternoon,\nthought I read in the security section (of 49 CFR) that a site specific plan was required. And during recent\nI would like to ask a question about security plans. Is the security plan required to be site specific? In the past I\nPHMSA audits we have been asked to produce a site specific plan and documented training on the plan.\nt a meetina todav at the CGA it was stated that the phrase site specific is not found in 49 CFR. I reviewed 4\nFR 172.700 throuch 172.800 (Suboan H and I andi did not tind a reterence\nDoes PHMSA require a site specific plan and if so, what is the CFR reference?\nThank you for your response.\nJohn Anderson\nAirgas-SAFECOR\nCheyenne, WY 82003\nP. O. Box 20067\nFax 1-307-778-7497\nPhone 1-307-778-8809\njohn.anderson@airgas.com\n7/21/2006","truncated":false,"body_characters":4692}