Transcript Document

TOOLKIT FOR HAZARDOUS MATERIALS
TRANSPORTATION EDUCATION
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This work is sponsored by the U. S. Department of Transportation
Pipeline and Hazardous Materials Safety Administration
(PHMSA). It was conducted through the Hazardous Materials
Cooperative Research Program (HMCRP), which is administered
by the Transportation Research Board of the National Academies.
Prepared by
3 Sigma Consultants, LLC
909 Edenbridge Way, Nashville, TN 37215
Module 7: Security of Hazmat
Transportation Shipments
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Learning Outcomes
At the end of this module students will be able to:
1. Explain the threats posed against hazmat during
all phases of transport.
2. Locate the key regulations governing the security
of dangerous goods shipments.
3. Describe the general principles of ensuring
hazmat shipment security.
4. Illustrate specific examples of security measures
for each mode of transportation.
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Topics
• Transportation system security concepts
• Regulatory requirements for hazmat shipment security
• Motor carrier security
– FMCSA Field Operational Test of hazmat safety and security
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Rail security
Maritime security
Air cargo security
Pipeline security
Customs‐Trade Partnership Against Terrorism (C‐TPAT)
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Role of Transportation
• Resource
– Response
– Evacuation
– Recovery
• Target
• Weapons delivery
Source: Volpe National Transportation Systems Center
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Securing Assets in Transport
• Ritter et al, Securing Global
Transportation Networks, McGrawHill, 2007, Chapter 6
• Five Focus Areas:
– Maintain chain of custody
– Confirm security practices of partners
in chain
– Verify credentials of personnel in
chain
– Verify controlled physical access to
assets
– Emergency
preparedness/resilience/redundancy
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General Principles of Dangerous Goods Security
• Natural disasters and theft are
greater threats than terrorism and
use of hazmat as weapons of mass
destruction (WMDs), although the
latter should not be ignored.
• Measures that improve cargo
security in general are equally
applicable to hazmat shipment
security.
• There are some hazmat-specific
security requirements and programs.
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USDOT Hazmat Security Regulations
• 49 CFR § 172.800-822 requires development and implementation of plans
to address security risks related to the transportation of hazardous
materials in commerce.
• § 172.800 lists specific quantities of various hazard classes/divisions that
trigger this requirement.
• Components of a security plan (§ 172.802):
– assessment of transportation security risks, including site-specific risks where
materials are prepared for transport, loaded, or stored incidental to transport
– personnel, unauthorized access, and en route security measures
– job title of the senior management official responsible for overall development and
implementation of the security plan
– security duties for each position or department that is responsible for
implementing the plan
– plan for hazmat employee security training
• § 172.820 requires additional planning for transportation by rail,
primarily related to dangerous goods routing (see module 4).
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USDOE Hazmat Security Regulations
• DOE requires establishment and maintenance of a physical
system for protection of special nuclear material at fixed sites
and in transit, and of plants in which special nuclear material
is used.
• The system must protect against acts of radiological sabotage
and prevent the theft or diversion of special nuclear material.
• The in-transit protection must include:
– en route telephone or radio communication
– minimization of transit time
– screening of employees involved in transport
• See 10 CFR Part 73 for complete details
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Security Guidelines for the Transportation
of Certain Hazardous Materials Cargo by
Commercial Motor Vehicles
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Applicability of These Guidelines
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Radioactive Materials – A highway route-controlled
quantity of a Class 7 (radioactive) material, as defined in
Section 173.403 of the Hazardous Materials Regulations;
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Explosives – More than 25kg (55 pounds) of a Division 1.1,
1.2, or 1.3 (explosive) material;
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Toxic by Inhalation (Division 2.3 and 6.1) Materials
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A shipment of compressed or refrigerated liquid methane
or natural gas or other liquefied gas in a bulk packaging
having a capacity equal to or greater than 13,248 L (3,500
gallons) for liquids or gases.
Source: Transportation Security Administration
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Management Guidelines
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Company Security Plans
Security Awareness
Security Plan Maintenance Expectations
Reporting Information
Source: Transportation Security Administration
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Operational Guidelines
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Facilities
Shippers
Drivers
Terminals
Consignees
Source: Transportation Security Administration
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Hazmat Facilities
1. Security measures should make it as difficult as possible
for a terrorist to interfere with your company’s
transportation operations and cargo within your
facilities.
2. Secure all entry and exit points of your facility.
3. Develop and maintain an employee ID program.
4. Erect and maintain security fencing around the
perimeter of your property.
5. Keep entry doors and entrances secure and locked if fire
codes permit.
6. Have visitors sign-in and show ID and wear a visitor pass.
Maintain the visitor roster for 12 months.
Source: Transportation Security Administration
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Hazmat Shippers
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During cargo loading, monitor loading and to the extent
operations allow, provide carrier with a safe and secure
location for loading.
Establish an overdue time for the carrier at final destination
and follow up when the carrier is late for final delivery or
overdue at in-transit points on their route.
When a carrier exits your facility, be aware of any possible
surveillance of your facility, or inappropriate behaviors or
actions that may occur during this time.
Remind the carrier about established stopping and parking
procedures, and caution them not to make any
unscheduled stops.
Be aware of possible “ruses.” If you are unsure if a police
officer is real, call 911 and ask.
Source: Transportation Security Administration
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Hazmat Drivers
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When leaving a facility, be aware of any possible
surveillance of the facility or truck. Criminal surveillance
often begins at, or within a mile of trip origin.
Have a communication device with you at all times.
Do not make any unscheduled stops.
Report any suspicious activities or emergencies to law
enforcement authorities.
Report any suspicious activities to dispatch.
Remain particularly observant for suspicious activities in
and around refueling locations, intermodal terminals,
bridges, and tunnels.
Source: Transportation Security Administration
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FMCSA Field Operational Test
• Objective -- quantify the security
costs and benefits of applying
technology and improved
enforcement to selected hazmat
transportation risk areas:
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Driver verification
Off-route vehicle alerts
Stolen vehicles
Unauthorized drivers
Cargo tampering
Suspicious cargo deliveries
• Conducted in 2002-2003
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FOT Framework
Source: FMCSA
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Selection of Technologies for Operational
Scenarios
Source: FMCSA
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Source: FMCSA
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Panic Buttons
Dash-mounted Panic Button
Wireless Panic Button
Source: FMCSA
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Biometric Identification
Source: FMCSA
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Remote Cargo Locks
Source: FMCSA
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Electronic Cargo Seals
Smart Seal Tag
Source: FMCSA
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Geofencing
Source: FMCSA
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Trailer Tracking
Trailer Tracking Subsystem
Tethered Device
Source: FMCSA
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Some FOT Results
Source: FMCSA
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Summary of FOT Findings
Source: FMCSA
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TSA HME Threat Assessment Program
• The Patriot Act (2001) prohibits states from issuing a license
to transport hazardous materials in commerce unless a
determination has been made that the driver does not pose a
security risk.
• The TSA HME Threat Assessment Program conducts a security
threat assessment for any driver seeking to obtain, renew, or
transfer a hazardous materials endorsement (HME) on a stateissued commercial drivers license (CDL).
– The risk assessment include checks of criminal history records, legal
status, and relevant international databases.
Source: Transportation Security Administration.
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Rail Security Issues
• Open access and high ridership (passenger rail)
• Types and volumes of hazardous materials shipped
on freight rail
• Interconnectivity of the rail system
Source: Federal Railroad Administration, Federal Railroad Administration Action Plan for Addressing
Critical Railroad Safety Issues. May 16th 2005
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Steps Taken to Improve Rail Security since 9/11
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Perform risk assessments
Conduct emergency drills
Develop security plans
Security Training
Images from Transportation Security Administration and Federal Transit Administration.
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Requirements for Rail Carriers of Hazmat
• Compile data, by route and line segment, on geographic location
of hazmat routes and the total number of shipments by UN
number.
• Identify practicable alternative routes.
• Identify security risks to high-consequence targets along the
hazmat routes.
• Analyze the safety and security risks for the railroad facilities and
high-consequence targets along the routes.
• Compare the safety and security risks on the primary and
alternative routes.
• Use the analysis described above to select the practicable route
posing the least overall safety and security risk.
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Additional Requirements for Hazmat
• Conduct a comprehensive review of route selection
determinations every 3 years.
• In developing security plans required under the HMR, address
the security risks of shipments delayed or temporarily stored
in transit.
• Notify consignees of any significant unplanned delays
affecting the delivery of the hazmat.
• Work with shippers and consignees to minimize the time a rail
car containing hazmat is placed on track awaiting pick-up,
delivery, or transfer.
• Conduct security visual inspections at ground level of rail cars
containing hazardous materials to check for signs of
tampering or the introduction of an IED.
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TSA Rail Transportation Security Requirements
• 49 CFR Part 1580, applies to shippers, receivers, and carriers
of rail security sensitive materials shipped by rail
• Imposes following principal requirements on these parties:
– Must allow TSA/DHS to inspect operations for compliance with
security directives
– must designate and use a primary and at least one alternate Rail
Security Coordinator (RSC)
– must have procedures in place to determine the location and shipping
information for each rail car under its physical custody and control
that contains rail security-sensitive materials [see § 1580.103 (3)(c)]
– must immediately report potential threats and significant security
concerns to DHS by telephoning the Freedom Center at 1-866-6155150.
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TSA Chain of Custody and Control Requirements
• A rail hazardous materials shipper, carrier, or receiver
transferring custody of a rail car containing rail securitysensitive materials must:
– physically inspect the rail car before loading or unloading for signs of
tampering, including closures and seals; other signs that the security
of the car may have been compromised; suspicious items or items that
do not belong, including the presence of an improvised explosive
device
– keep the rail car in a rail secure area until the carrier or receiver takes
physical custody of the rail car
– not leave the rail car unattended in a non-secure area at any time
during the physical transfer of custody
– document the transfer of custody
• See § 1580.107 for exact duties imposed on the various
parties, both within and outside of a high threat urban area
(HTUA).
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Asset/Cargo Tracking
• Attributes
– Real-time tracking through
intermodal chain
– Focus on assets & cargo
– Internet based information
distribution
• Purpose
– Data availability through
intermodal logistics information
management system
– Real-time cargo and transport
asset information
– Origin-destination asset and
cargo security
Data Acquisition - Chassis Surveillance
GPS
Constellation
Aeris
Cellular
NYU 980
765434
Container Tag
RFID Reader
E
Bare/Covered
Sensor
J560
Connector
TEID
EID
Tether
Sensor
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Maritime Security
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Port Security Challenge
• Over 95 percent of the nation’s overseas cargo moves through
our ports.
• In 2003, there were 76 million recreational boaters in the
United States.
• Worldwide, 5.8 billion tons of goods were traded by sea in
2001. This accounts for over 80 percent of world trade by
volume.
• Over 318 billion gallons of petroleum products are shipped in
vessels on U.S. waterways in a year.
• Cruise ships calling at U.S. ports carry over 6 million
passengers per year
Source: MarAd
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Port Security Measures July 1, 2004
• Security assessments and plans
– 9500 vessels
– 3500 facilities
• Implementation of plans
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increased identification checks
additional canine detection teams
expanded baggage and passenger screening
strategically placed perimeter fencing equipped with
newly installed surveillance cameras
Source: Secure Seas, Open Ports: Keeping our waters safe, secure and
open for business, DHS, June 21, 2004
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Source: Secure Seas, Open Ports: Keeping our waters safe,
secure and open for business, DHS, June 21, 2004.
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Layers of Maritime Security
Source: Secure Seas, Open Ports: Keeping our waters safe, secure
and open for business, DHS, June 21, 2004.
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Coast Guard enforcing a security zone around a moored LNG tanker
GMU School of law, The CIP Report, Issue 104, March 2011.
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Safety and Security
• Maritime Transportation Security Act of 2002 (MTSA)
– Requires vessels and port facilities to conduct vulnerability
assessments and develop security plans
– Required possession of Transportation Worker Identification
Credential (TWIC)
• Safe Port Act of 2006
– Added requirements to MTSA to improve security of U.S. ports
– Oversight must balance security and commerce needs
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TSA Air Cargo Security Program
• The 9/11 Act (2007) requires TSA to establish a system to
ensure 100% screening of both domestic and international
inbound cargo on passenger aircraft.
• TSA has provided air carriers a path toward achieving 100%
screening of international inbound cargo through risk-based
analysis of shippers and shipments.
– The National Cargo Security Program (NCSP) is an important
component of this risk-based strategy.
– Recognition of commensurate NCSP that will allow inbound air carriers
departing from countries with programs commensurate to the U.S. to
follow only the security requirements of host governments (NCSP
Recognition).
Gary Lupinacci, TSA’s Efforts to Ensure 100% Screening of Air Cargo on Passenger Aircraft, TSA/DHS, May
2012, http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf
(accessed Feb 2013).
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NCSP Recognition Process
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Host Country provides security program to TSA
TSA reviews program
Site visit is planned for review by both parties
If program is deemed to be commensurate, TSA confers
formal recognition of a country’s NCSP
• Renewal of this recognition is at a pre-determined time
interval
Gary Lupinacci, TSA’s Efforts to Ensure 100% Screening of Air Cargo on Passenger Aircraft, TSA/DHS, May
2012, http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf
(accessed Feb 2013).
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Implementation of Air Cargo Screening
• The 100 percent cargo screening rule has been in force for
domestic passenger flights since 2010.
• Enforcement of 100 percent cargo screening for inbound
international passenger flights to the U.S. began in December
2012.
• “Screening” does not necessarily mean “scanning.”
– evaluate the contents, sender and destination of packages
– do more intensive inspections on high-risk cargo
– establish a secure chain of custody from the shipping facility to the
aircraft
• The key is to identify trusted shippers – and then focus on
screening suspicious packages.
• Achieving 100 percent screening of all-cargo aircraft remains a
challenge.
A Primer On Air Cargo Security, http://www.aviationpros.com/article/10771368/a-primer-on-aircargo-security, Sept 2012 (accessed Feb 2013).
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2010 San Bruno Pipeline Explosion
Photo by Thomas Hawk, Sept 19, 2010 (some rights reserved).
http://www.flickr.com/photos/thomashawk/5006343716
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2010 San Bruno Pipeline Explosion
• September 9, 2010, 6:11 p.m.
• 30-inch steel natural gas pipeline
• 2 mi west of San Francisco International Airport near
Skyline Boulevard and San Bruno Avenue
• 8 deaths, 6 missing, 60 injured
• 37 homes destroyed
• The pipe was a main transmission line that fed off to
smaller distribution lines
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US Pipeline Network
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Pipeline Releases
• Accidental pipeline releases result from a variety of causes
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outside force (e.g., third-party excavation)
corrosion
mechanical failure
control system failure
operator error
natural forces, such as floods and earthquakes
• According to the DOT, of 183 gas pipeline accidents reported
in 2002, outside forces were by far the leading cause,
accounting for 46% of reported failures.
• Outside forces was also the leading cause of the 140 oil
pipeline accidents in 2002, responsible for 32% of failures.
Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities
and Current Policy Issues, Congressional Research Service, Feb 2004.
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Security Aspects of Pipeline Releases
• A single pipeline incident can be catastrophic and therefore
are attractive terrorist targets.
• However, accidental releases happen much more frequently
than intentional ones.
• Pipeline releases generate substantial scrutiny of pipeline
regulation and increased state and community activism
related to pipeline safety and security.
• Fortunately, the pipeline industry has extensive experience
responding to releases and generally does so relatively
quickly.
Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities
and Current Policy Issues, Congressional Research Service, Feb 2004.
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Pipeline Security: Vulnerability
• Like any physical system, pipelines are vulnerable to vandalism and
terrorist attack.
– The physical plant of these facilities may be damaged with explosives or by
other mechanical means, disrupting flows and causing a release of pipeline
contents.
– Computer control systems may be “cyber-attacked”
– Both physical and cyber attack may happen at the same time
• Some pipelines may also be indirectly disrupted by other types of terror
strikes, such as attacks on regional electricity grids or telecommunications
networks, which could in turn affect dependent pipeline control and safety
systems.
• Since pipelines supply fuel for vehicles, power plants, aircraft, heating,
military bases and other uses, serious disruption of a pipeline network
poses additional “downstream” risks.
Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities
and Current Policy Issues, Congressional Research Service, Feb 2004.
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Pipeline Security: Attack Examples
• Some attacks and threats against pipelines and related
infrastructure have occurred in the United States.
• In 1997, Texas police prevented the bombing of natural gas
storage tanks at a processing plant by Ku Klux Klan members
seeking to create a diversion for a robbery (to finance other
terrorist actions).
• In 1999, Vancouver police arrested a man planning to blow up
the trans-Alaska pipeline for personal profit in oil futures. He
was found with high explosives and timers for 14 bombs.
• In 2001, a vandal’s attack with a high-powered rifle, also on
the trans- Alaska pipeline, forced a two-day shutdown and
caused extensive economic and ecological damage.
Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities
and Current Policy Issues, Congressional Research Service, Feb 2004.
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Pipeline Security Activities and Policies
of Federal Agencies
• The Transportation Security Administration (TSA), within the
Department of Homeland Security (DHS), is the lead federal
agency for security in all modes of transportation — including
pipelines.
• TSA expects pipeline operators to maintain security plans
based on security guidance initially circulated in 2002.
• PHMSA is the lead federal regulator of pipeline safety and
security. TSA and PHMSA currently cooperate on security
inspections, but many in industry are still concerned about
the possibility of redundant, conflicting regulatory regimes.
Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities
and Current Policy Issues, Congressional Research Service, Feb 2004.
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Pipeline Security Tradeoffs
• Various industry representatives state that they need clear
and stable definitions of pipeline asset criticality, so they will
know exactly what assets to protect, and how well to protect
them.
– Otherwise, the pipeline industry risks hardening too many facilities,
hardening the wrong facilities, or both.
– Either outcome would increase ultimate costs to consumers without
commensurate security benefits, and could potentially divert scarce
security resources from better uses within or outside the pipeline
industry (e.g., securing electric power stations).
Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activities
and Current Policy Issues, Congressional Research Service, Feb 2004.
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Customs‐Trade Partnership Against Terrorism (C‐TPAT)
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Sponsored by U.S. Customs and Border Protection, DHS
A voluntary government‐business initiative to build
cooperative relationships that strengthen and improve
overall international supply chain and U.S. border security.
Includes more than 10,000 certified partners that span the
gamut of the trade community.
The partnership establishes clear supply chain security
criteria for members to meet and in return provides
incentives and benefits like expedited processing.
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•
companies sign an agreement to work with CBP to protect the supply
chain, identify security gaps, and implement specific security
measures and best practices
partners provide CBP with a security profile outlining the specific
security measures the company has in place
An emerging focus: Mutual Recognition Arrangements
Source: U.S. Customs and Border Protection, DHS.
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Key Takeaways
• Hazmat shipments and facilities are a security concern
because of their potential to be used as means of attacking
other targets.
• Measures that improve cargo security in general are equally
applicable to hazmat shipment security.
• The most effective security enhancement procedures are
multi-layered systems that address each aspect of
vulnerability.
• En route security is challenging due to the many uncontrolled
factors involved.
• Industry and government are cooperating to enhance hazmat
security.
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Student Exercises
1. Select one of the technologies tested in the FMCSA hazmat
security field operational test and discuss its application
costs and benefits.
2. For three security enhancing technologies assigned by the
instructor, determine the impact of each on the
transportation organization’s efficiency and safety.
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Resources for Support and Additional Learning
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Ritter et al, Securing Global Transportation Networks, McGraw-Hill, 2007.
Recommendations for Bridge and Tunnel Security, FHWA and AASHTO, September
2003 (http://www.fhwa.dot.gov/bridge/security/brptoc.htm).
FEMA 426, Risk Management Series, Reference Manual to Mitigate Potential Terrorist
Attacks Against Buildings, Federal Emergency Management Agency, Washington, DC,
December 2003.
Federal Motor Carrier Safety Administration, Hazardous Material Transportation
Safety and Security Field Operational Test (FOT) Final Report – Deployment Team,
FHWA-OP-03-XXXX, USDOT, Washington, DC, August 31, 2004.
http://www.fmcsa.dot.gov/documents/hazmat/fot/HMFOT-Final-Report.pdf
Parfomak, Paul W., Pipeline Security: An Overview of Federal Activities and Current
Policy Issues, RL31990, Congressional Research Service, Washington, DC, Feb 2004.
http://www.fas.org/sgp/crs/RL31990.pdf.
DeBlasio, Allan J., et al., Effects of Catastrophic Events on Transportation System
Management and Operations: Cross Cutting Study, U.S. Department of
Transportation, Volpe National Transportation Systems Center, Cambridge, MA,
January 2003.
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