Rail Hazmat


HM-232

Overview and Security Plan Requirements

In March 2003, the Department of Transportation (DOT) issued regulations to enhance the security of hazardous materials transported in commerce. These regulations, known as HM-232, require shippers of certain hazardous materials to develop and adhere to a transportation security plan and train relevant employees regarding the security plan. In March 2010, DOT issued a Final Rule Adjustment, narrowing the scope of hazardous materials subject to HM-232 and modifying certain security plan components and training requirements.

The security plan must include a site-specific transportation security risk assessment and appropriate measures to address the assessed risks. Additionally, each security plan must include the following components:

  • Personnel Security – Measures to confirm information provided by job applicants hired for positions that involve access to and handling of the hazardous material(s) covered by the security plan.


  • Unauthorized Access – Measures to address the assessed risk that unauthorized persons may gain access to the hazardous material(s) covered by the security plan.


  • En Route Security – Measures to address the assessed security risks associated with shipments of the hazardous material(s) covered by the security plan en route from origin to destination, including shipments stored incidental to movement.
Applicability

Each person who offers for transportation in commerce or transports in commerce one or more of the hazardous materials delineated in the chart below must develop and adhere to a hazardous materials transportation security plan. Note that a “large bulk quantity” is any quantity greater than 3,000 kg (6,614 pounds) for solids or 3,000 liters (792 gallons) for liquids and gases in a single packaging such as a cargo tank motor vehicle, portable tank, tank car, or other bulk container.

Hazard Class/Division

Type

Threshold Quantity

Division 1.1, 1.2, and 1.3

Explosives

Any Quantity

Division 1.4, 1.5, and 1.6

Explosives

Any Quantity Requiring Placarding

Division 2.1

Flammable Gases

Large Bulk Quantity

Division 2.2

Nonflammable Gases

Large Bulk Quantity with Subsidiary Hazard of Division 5.1 Oxidizer

Division 2.3

Poisonous Inhalation Hazard (PIH)

Any Quantity

Class 3 and Division 4.1

Desensitized Explosives

454 kg (1,001 pounds) or Greater in a Single Transport Vehicle or Freight Container

Class 3

Flammable Liquids

Large Bulk Quantity in Packing Group I or II

Division 4.2

Spontaneously Combustible

Large Bulk Quantity in Packing Group I or II

Division 4.3

Dangerous When Wet

Any Quantity

Division 5.1

Oxidizers

Large Bulk Quantity in Packing Groups I and II

Division 5.2

Organic Peroxides

Any Quantity of Organic Peroxide, Type B, Liquid or Solid, Temperature Controlled

Division 6.1

Poisonous Materials Other than PIH

Large Bulk Quantity in Packing Groups I, II, and III

Class 8

Corrosive Materials

Large Bulk Quantity in Packing Group I

Class 9

Miscellaneous Hazardous Materials

Not Subject

Training Requirements

  • Security Awareness Training – 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, including a component covering how to recognize and respond to possible security threats. Security awareness training must be administered within 90 days of employment, within 90 days of a change in job function, and at least every 3 years.

  • In-Depth Security Training – Each hazmat employee must be trained concerning their facility’s security plan and its implementation. In-depth security training must include company security objectives, organizational security structure, specific security procedures, specific security duties and responsibilities for each employee, and specific actions to take by each employee in the event of a security breach. In-depth security training must be administered within 90 days of employment, within 90 days of a change in job function, and at least once every 3 years. If the security plan is revised or updated during that 3 year cycle, each hazmat employee must receive training regarding the revised or updated security plan within 90 days of its implementation.