University Department of Transportation Security Plan

Transcription

University Department of Transportation Security Plan
SAINT JOSEPH’S UNIVERSITY SECURITY PLAN FOR THE
TRANSPORTATION and STORAGE OF HAZARDOUS MATERIALS
Issue Date: December 27, 2006
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Revised August, 2010
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
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Please direct any questions or comments about the applicability of this document to the Director of Health
Safety and Environment at 610 660 3037.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
TABLE OF CONTENTS
Section
Page
1.0 Plan Certification......................................................................................................................................1
2.0 Introduction .............................................................................................................................................3
2.1 Applicability ........................................................................................................................................... 4
2.2 Definitions.................................................................................................................................................4
2.3 Hazard/Risk-Based Management in the Hazardous Materials Program.........................................5
3.0 Designated Security Contact...................................................................................................................7
4.0 Personnel Security....................................................................................................................................8
5.0 Unauthorized Access ..............................................................................................................................8
6.0 En-route Security......................................................................................................................................9
7.0 Vulnerability Assessments.....................................................................................................................10
8.0 Employee Awareness.............................................................................................................................10
Appendices
Appendix A: Security Plan Training Certification............................................................................13
Appendix B: Additional References for Security-Related Information...........................................15
Appendix C: Additional References for Security-Related Information………………………………………..16
Appendix D: Regulatory References and Reporting Forms………………………………………...................18
Core Plan Prepared by:
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Turning Bird Consulting, Ltd
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
Abbreviations
ARCHIE – a personal computer based program, “Automated Resource for Chemical Incident Evaluation” CDC –
Center for Disease Control CFR – Code of Federal Regulations DOT – U.S. Department of Transportation EPA –
Environmental Protection Agency FEMA – Federal Emergency Management Agency HM – Hazardous Material
HAZMAT – Hazardous Material HW – Hazardous Waste RSPA – DOT’s Research and Special Programs
Administration SP – DOT required hazardous material transportation Security Plan WMD – Weapons of Mass
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Destruction
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
DOT Security Plan
1.0 Saint Joseph’s University
Administration Certification
This written transportation Security Plan (SP) has been prepared to protect the security of Hazardous Materials (HM)
shipments during transportation in commerce, as defined by the U.S Department of Transportation, while under the
control of Saint Joseph’s University. Appropriate personnel at Saint Joseph’s University have reviewed, and approved
of this Security Plan. The procedures in this Plan will be implemented and will be amended, as necessary, due to
expansions, renovations, modifications, and improvements at the campus.
Signature: _________________________________________________
Date: _______________________
Saint Joseph’s University Howard R. Heim, QEP Director of Health and Safety / Environmental Compliance
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Officer 5600 City Avenue Overbrook Hall Philadelphia, PA 19131 610 660 3037 610 660 3019 (Fax)
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
2.0 Introduction
This written Security Plan has been developed to comply with the requirements outlined in 49 CFR Part 172
Hazardous Materials Security Requirements for Offerors and Transporters of Hazardous Materials as promulgated by
the U.S Department of Transportation’s (DOT) Research and Special Programs Administration (RSPA). Satisfying
the needs of our highly competitive industrialized society, while maintaining an acceptable level of safety at a
reasonable cost, is a regulatory challenge that RSPA has met through its hazard/risk-based approach to the
management of the hazardous materials transportation.
Saint Joseph’s University is committed to the safety and security of every hazardous material shipment offered for
shipment and/or transportation by the Saint Joseph’s University and its contracted transportation companies. A
Security Plan (SP) is required at Saint Joseph’s University since hazardous materials (HM) as defined by DOT include
hazardous waste (HW) as listed in the DOT HM Table in 49 CFR Part 172.101.
The U.S Transportation Security Administration has stated international terrorist groups have shown an interest in
obtaining hazardous materials, such as hazardous and infectious waste through both legal and illegal means in order
to use such material in this country as weapons of mass destruction (WMD) against both civilian and military targets.
Non-secure storage and shipment of DOT hazardous materials by Saint Joseph’s University may place the University,
its employees, students and neighbors at an elevated risk of terrorist attack. This SP addresses measures that can and
will be taken to reduce such risks to terrorist attacks from occurring or act as an effective deterrent.
In order to enhance the security of hazardous materials, all employees must take the risk of terrorist attack against
hazardous material shipments seriously. It is the policy of Saint Joseph’s University that all employees make every
effort, on a daily basis, to ensure the security of HM and that any unusual or questionable acts are immediately
reported to SJU Department of Public Safety by calling:
Public Safety and Security
John Henfey , Director
5600 City Avenue, Barbelin Building
Philadelphia, PA 19131
610 660 1111
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The following written Security Plan presents Saint Joseph’s University’s approach to enhance security on the campus
grounds and to specify additional procedures that HM shippers, receivers and drivers will follow in an effort to
prevent a terrorist incident from occurring. All employees who ship or transport HW must read it, become familiar
with, and understand its requirements and implement its procedures at all times as a condition of employment. The
security of all HM including HW whether in storage, awaiting pick up or on route in transportation, is a top priority.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
2.1 Applicability
The determination and identification of hazardous materials that are received by, stored at or shipped from Saint
Joseph’s University, which meet the criteria for the development of a Security Plan generally will be found in the
following campus operations: Receipt and Storage of Fuel oils, propane and gasoline deliveries;
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Hazardous Waste shipments;
Receipt and storage of Hazardous Material shipments exceeding 1000 pounds (e.g. Pallets of cleaning
chemicals);
Receipt and storage of substances, which are considered toxic by inhalation, in quantities exceeding 1 liter
(1.06 qt) per package (e.g. Pesticides, Gaseous Chlorine etc.);
Receipt and storage of highway route controlled quantity of Class 7 (Radioactive) material;
Receipt, storage of acutely hazardous materials for the Chemistry and Biology Departments;
Receipt, storage and disposal of select agents or toxins regulated by the Center for Disease Control.
2.2 Definitions
The terms hazard, risk, risk analysis and hazard or risk management have many forms and meanings. For HM safety
the following terms are understood to mean the following:
Hazard is the inherent characteristic of a material, condition, or activity that has the potential to cause harm to
people, property, or the environment.
Hazardous Material Employee is the Saint Joseph’s University employee who handles hazardous waste or other
DOT regulated hazardous materials.
Risk is the combination of the likelihood and the consequences of a specified hazard being realized. It is the measure
of harm or loss associated with an activity.
Likelihood is expressed as either a frequency or a probability. Frequency is a measure of the rate at which events
occur over time ( e.g., events/year, incidents/year, deaths/year, etc.). Probability is a measure of the rate of a possible
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event expressed as a fraction of the total number of events (e.g., one-in-a-million, 1/1,000,000, or 1 x 10 ).
Consequence is the direct effect of an event, incident or accident. It is expressed as a health effect (e.g., death,
injury, exposure), property loss, environmental effect, evacuation, or quantity spilled.
Hazard Analysis is the identification of material properties, system elements or events that lead to harm or loss. The
term hazard analysis may also include evaluation of consequences from an event or incident.
Risk Analysis is the study of risk in order to understand and quantify risk so it can be managed.
Risk Assessment or Risk Characterization is determination of risk context and acceptability, often by comparison
to similar risks.
Quantitative Risk Analysis incorporates numerical estimates of frequency or probability and consequence. In
practice a sophisticated analysis of risk requires extensive data which are expensive to acquire or often unavailable.
Fortunately few decisions require sophisticated quantification of both frequency and consequences.
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Relative Risk Analysis means that a risk is evaluated in comparison to another risk. The type of risk analysis used
should be appropriate for the available data and to the exposure, frequency, and severity of potential loss.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
Risk Management is the systematic application of policies, practices, and resources to the assessment and control
of risk affecting human health and safety and the environment. Hazard, risk, and cost/benefit analysis are used to
support development of risk reduction options, program objectives, and prioritization of issues and resources. A
critical role of the safety regulator is to identify activities involving significant risk and to establish an acceptable level
of risk. Near zero risk can be very costly and in most cases is not achievable.
An Acceptable Level of Risk for regulations and exemptions is established by consideration of risk, cost/ benefit
and public comments. Relative or comparative risk analysis is most often used where quantitative risk analysis is not
practical or justified. Public participation is important in a risk analysis process, not only for enhancing the public’s
understanding of the risks associated with hazardous materials transportation, but also for insuring that the point of
view of all major segments of the population-at-risk is included in the analyses process. Risk and cost/benefit analysis
are important tools in informing the public about the actual risk and cost as opposed to the perceived risk and cost
involved in an activity. Through such a public process RSPA establishes hazard classification, hazard communication,
packaging, and operational control standards.
2.3 Hazard/Risk-Based Management in the HM Program
2.3.1 Regulatory Standards
The HM regulatory system is a prevention-orientated risk management system, which focuses on the identification
of a potential hazards and the reduction of the probability and quantity of a hazardous material release. Hazardous
materials are categorized into hazard classes and packing groups based upon hazard analysis and experience. The
applicable regulations require each shipper to classify a material in accordance with these hazard classes and packing
groups; the process of classification is itself a form of hazard analysis. In addition, the regulations require a shipper
to communicate the most significant findings through the use of the hazard class, packing group and the proper
shipping name on the shipping paper and the use of labels on packages and placards on transport vehicle.
A HM is assigned to one of three packing groups based upon its degree of hazard, ranging from a highly hazardous
packing group I to a mildly hazardous packing group III. The quality, resistance to damage, and performance
standards of the packaging used for each packing group are appropriate for the specific hazards of the material being
transported.
2.3.2 Exemptions of the Hazardous Materials Regulations
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In the Hazardous Materials Transportation Act of 1974, Congress created a risk management program able to
authorize alternative regulations. The purpose of these alternative regulations, is to facilitate advancement through
the implementation of more efficient methods and new technologies that provide for a level of safety greater than or
equal to that provided by the original regulations. The procedural regulations governing RSPA’s exemptions program,
published under Section 107.103 of Title 49 of the Code of Federal Regulations (49 CFR 107.103), require that all
applications for exemption be accompanied by a detailed safety analysis, i.e. data and documentation that
substantiates a finding that the sought after exemption will provide a level of safety greater than or equal to that
provided under the existing regulations. The type of safety analysis required to support cause for an exemption varies
greatly, from a complex risk analysis of complex packing systems involving new technological advancements to a
simple comparison of minor variations in packaging or operational controls. There is risk present in the new
technologies or materials, which is often difficult to evaluate and so may require extensive risk analysis.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
2.3.3 Emergency Preparedness and Response
Should an incident occur, RSPA’s hazardous material program includes elements designed to mitigate the
consequences of a release. To provide guidance on hazards, emergency actions, and protective action decision factors
and distances, information is published in the “Emergency Response Guidebook,” by the RSPA and distributed to
first responders. The information is tailored to reflect the risks of each material. In an effort to support emergency
preparedness and response planners on both a state and local level, RSPA, the Federal Emergency Management
Agency (FEMA), and the Environmental Protection Agency (EPA), developed the “Handbook of Chemical Hazards
Analysis Procedures,” and a personal computer based program, “Automated Resource for Chemical Incident
Evaluation” (ARCHIE). Through its Planning and Training Grants the RSPA provides funding to State and local
agencies/ municipalities for emergency preparedness and for planning and training aimed at mitigation of the
consequences associated with hazardous materials incidents.
2.3.4 Information/ Data Bases
Information is critical to the effective use and application of hazard/risk analyses. RSPA has improved the
information/data bases used to determine which risks in the transportation of hazardous materials appear to be the
greatest, and to identify corrective actions needed to address the major contributors to those risks.
2.3.5 Compliance
The RSPA uses a system of risk management to prioritize compliance activities and address the risks associated with
non-compliance. The RSPA places a greater emphasis on the compliance of hazardous materials and packaging
associated with a high hazard to the public such as poisons, flammable gasses, explosives, and poison inhalation
hazard liquids.
When non-compliant packaging are found, a risk and cost/benefit assessment is performed to aid in determining
the appropriate course of action, such as recall, down-rating or use restriction, necessary to protect the safety of the
public.
The RSPA has developed a “Procedure for Removal of Nonconforming Hazardous Materials Packaging from
Service” that delineates a process and assessment guidelines for nonconforming packaging.
2.3.6 Outreach
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The communication of regulatory requirements and their changes to industry and the general public is an integral
part of risk management. Clear and consistent information dissemination is a top priority with RSPA.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
3.0 Designated Security Contact
All-security related questions, information, and reports of suspicious activity or incidents involving the shipment of
HM and HW at Saint Joseph’s University must be reported immediately to:
Public Safety and Security
John Henfey, Director
5600 City Avenue, Barbelin Building
Philadelphia, PA 19131
The designated security contact will relay security related information immediately to the appropriate person or
persons within Saint Joseph’s University as well as to state local and federal law enforcement officials if appropriate.
In the case of a security emergency or incident, all information must be relayed immediately by the individual
responsible for HM’s storage and/or shipment security to appropriate parties and authorities. The designated Saint
Joseph’s University Security Contact must immediately alert state and local police authorities and the local Office of
the FBI of any security incident involving any violation of this SP, potential terrorist act or threat and/or other HM
incidents believed to be associated with terrorist organizations. The following emergency contact and/or first
responder numbers should be called in the event of a terrorist act:
Contact Information:
For Emergencies: General: Dial 911 and 1111 at the University
Other Contact Information:
Philadelphia Fire Department –
Hazardous Materials Unit
215-685-8061
Police Department
Township of Lower Merion
71 E. Lancaster Avenue
Ardmore, Pennsylvania 19003
Pennsylvania State Police:
Belmont Barracks
215 560 6200
FBI Local Office
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8 and Market Sts.
Philadelphia, PA
215 418 4000
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
4.0 Personnel Security
Security requirements for personnel with access to HW storage areas or who receive HM are further outlined below.
Saint Joseph’s University will implement the following procedures to ensure that HM employees do not pose a
security risk that in any way endangers a shipment or storage of HW or HM. These procedures apply to employees
(and applicants for employment) whose duties require initial and periodic HM training under existing federal
hazardous material regulations such as, HM shippers, HM receivers, HM handlers and HM drivers (commercial
driver’s license holder with hazardous material – endorsement).
Ensure that a background check for criminal activity and security risk is performed on all applicants for HM
employees;
Contact previous employers and references of all applicants for HM employees;
Investigate gaps in applicant employment history or any other information that seem suspicious,
To the extent possible, require at least ten years consecutive employment and/or education records for all HM
employees and applicants.
Ensure HM driver applicants have current CDL license with appropriate endorsement and other forms of
identification (e.g. current medical qualification certificates, etc.),
Verify that all HM employees and potential applicants for those positions are US citizens, or have appropriate legal
alien status and work authorization documents issued by the U.S Immigration and Naturalization Service,
Upon termination of employment of any HM employees; check out with facilities management, security and the
environmental health and safety office prior to departure. The purpose of which is to ensure the following
requirements are competed:
Collecting employee identification cards, photos or other items that demonstrate employment, keys to building
and access areas where HM and HW are stored;
Collecting any Saint Joseph’s University cell phones and/or two way radios;
Canceling all computer passwords and other access codes that would allow former employees to gain access to
HM and HW shipments or to sensitive information such as delivery schedules, routes and destination;
Updating Saint Joseph’s University records, web sites and other material that lists employees names and
removing their names and/or authorized access to HM and HW storage areas or shipments,
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Informing coworkers and other Saint Joseph’s University personnel and employees, information technology
personnel, product suppliers, and other appropriate department personnel when a former employee is no longer
authorized to access, ship or receive HM and HW shipments.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
5.0 Unauthorized Access
Preventing unauthorized person from gaining access to HM and HW storage areas is imperative. The Following
procedures will be followed to prevent unauthorized access to areas and locations where HM and HW is stored:
All outside visitors and vendors that are required to enter facilities where HM or HW are present must be known to
the Saint Joseph’s University employee or be able to produce photo identification;
All areas throughout the campus which house HM and HW must be secured by lock and key, Keys will be stored in a
secure area when unattended or not in use, such areas include; HW storage areas, HM Storage Areas, i.e. Chemistry
& Biology Chemical Storage rooms, Central Receiving, Pesticide storage, etc.;
All laboratories should remain locked when not in use, efforts should be taken to ensure that untrained/unauthorized
students are not left unattended in any and all laboratories, prep rooms and chemical stock rooms.
All Trucks and vehicles and related equipment containing or transporting HM or HW will be adequately secured by
lock and key at all times while on campus grounds. Keys will be stored in a secure area when unattended or not in
use;
Random and periodic inspections of trucks, vehicles and storage areas where HM and HW are located will be
conducted on a weekly basis to detect evidence of tampering, vandalism and to further demonstrate that Saint
Joseph’s University has an active terrorism deterrent program in place;
Trucks and vehicles will not be left unattended in unless secured by lock and key. The location of the HM or HW
must be communicated and approved by campus security;
Access to information regarding delivery schedules, routes and destinations must be limited to employees on a need
to know basis;
The status of and changes in the nation’s threat level as determined by the Department of Homeland Security will be
posted in the Department of Public Safety;
HM and HW shippers, receivers and drivers will be provided with periodic information on security precautions and
other terrorist and national security concerns; and
More stringent security precautions to prevent unauthorized access may be required when the nation’s threat level
increases.
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Hazmat employees will receive periodic information on security precautions for petroleum shipments.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
6.0 Enroute Security
Ensuring the protection and security of HM and HW shipments is of great concern, as it may provide a potential
opportunity for terrorist involvement. In an effort to enhance the security of HM and HW during shipments, Saint
Joseph’s University will enact the following procedures. All transportation companies utilized by the Saint Joseph’s
University including Saint Joseph’s University trucks and vehicles removing and/transporting HM and HW from the
campus will be reviewed to ensure that their SP addresses the following elements:
HM drivers will be required to conduct an inspection of their truck and/or vehicles for any unauthorized alterations,
tampering or any other suspicious activity. This inspection will be conducted at the beginning of each shift as a part
of normal daily pre-trip vehicle inspection,
HM drivers will conduct a “walk around” inspection of the transporting vehicle after each delivery or stop to ensure
that no unauthorized alteration, tampering or other suspicious activity has occurred.
At any time which the HM driver leaves the truck or transporting vehicle (e.g., break time, down time, end of shift,
etc.) they must ensure that the keys are removed from the ignition, the windows are fully rolled up and the doors are
locked and secured,
HM drivers are forbidden to pick up hitchhikers, allow any unauthorized person in the truck cab, stop for motorists
in distress or pull over at the behest of any person unless instructed to do so by a law enforcement official,
HM drivers must notify the dispatcher when deliveries fall more than one hour behind schedule e.g., traffic delays, etc.
Whenever a HM driver parks a motor vehicle for any reason other than loading or unloading, they must ensure that
the vehicle is parked in a well lit and safe area with reasonable visibility and security,
HM drivers should make every effort practicable, in order to minimize “ down time” during the assigned delivery
route,
HM drivers should not talk to unauthorized persons about the delivery route, delivery schedule or ultimate
destination of any HM or HW shipment,
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HM drivers should remain continually alert for any suspicious activities that may endanger the shipment (e.g. talkative
strangers inquiring about the shipment, roadside distractions such as disabled vehicles, occupants of vehicles pulling
along side the cargo tank motor vehicle attempting to catch your attention or distract you. Be especially aware of
vehicles with three or more male occupants).
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
7.0 Vulnerability Assessments
A vulnerability assessment will be conducted for each identified risk that ranks the risk according to DOT guidelines.
Each risk will be ranked according to hazard and exposure where the hazard ranking considers chemical properties
such as flammability, explosiveness, toxicity, vapor pressure, reactivity, and corrosivity. The exposure ranking
includes conditions such as predictability of shipments, proximity to public events, volume, population densities, trip
distances, and environmental conditions.
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The risk and vulnerability assessments will be maintained separately from the Saint Joseph’s University Security Plan
and will only be released to authorized personnel.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
8.0 Employee Awareness
All HAZMAT employees are responsible for understanding the security risks associated with transporting HM and
HW and to learn to identify and respond to those risks in the event of their occurrence. A security risk assessment
will be maintained separately from the Security Plan and will only be released to authorized personnel. In addition, all
hazmat employees or subcontractors who fail to read this Plan, understand its requirements and implement its
procedures at all times may be subject to termination of employment.
 This Security Plan is subject to change as circumstances or federal law requires. An updated copy of the
University’s Security Plan will be provided to all hazmat employees as soon as it becomes available.
 If there is any uncertainty regarding the written Security Plan, the security risk assessment or any other
security related matter, it is the duty of all hazmat employees to seek clarification from the University’s
designated security contact.
Understanding security risks and implementing the SP can act as an effective deterrent thus avoiding a potential
terrorist incident at Saint Joseph’s University. The training required on this SP is further outlined below:
8.1 Training
8.1.1 Security Awareness Training
The training requirements for HAZMAT employees are two-fold. First, all HAZMAT employees must under go the
standard, security awareness training, which covers the security risks associated with the transportation of hazardous
materials and methods designed to enhance transportation security. This training is an integral component of the
current DOT testing requirements, which every HAZMAT employee must undergo every three years or within 90
days of hiring. The DOT defines a HAZMAT employee as anyone who:
Operates a vehicle containing a hazardous material.
Loads, unloads, or handles a hazardous material.
Prepares hazardous materials for transportation.
Signs hazardous materials manifests.
Is responsible for the safety of a hazardous material shipment.
Tests, modifies, marks, repairs, or reconditions a hazardous material Packaging for shipment.
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Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
8.1.2 In-Depth Security Training
The second portion of the training section, In-depth security training, can be performed in house and requires that
HAZMAT employees be aware of specifics within the Security Plan and should cover the following:

Saint Joseph’s University Campus security objectives;
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Specific security procedures;
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Responsibility of HM shippers, receivers and drivers;
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Actions to be taken in the event of a security breach, and,

The organizational security structure.
Shippers, receivers, handlers and drivers are responsible for understanding the SP and executing the procedures
outlined in this plan and as described as below:
All HM shippers, receivers, handlers and drivers are responsible for understanding the security risks associated with
the storage and transportation of HM and HW and to identify and respond to those risks should they occur.
In addition, all HM shippers, receivers, handlers and drivers are required to read this SP, understand its requirements
and implement its procedures at all times. Failure to do so may be grounds for termination of employment.
This Security Plan is subject to change as circumstances of federal law requires. An updated copy of the University’s
Plan will be available to all HM impacted individuals as soon as it becomes available.
If there is any uncertainty regarding the written SP, or any other security related matter, it is the duty of all HM
shippers, receivers, handlers and drivers to seek clarification from the University’s designated security contact.
The Saint Joseph’s University will provide news, updates and other pertinent information relating to security matters
to HM shippers, receivers, handlers drivers on a regular basis.
8.1.3 NIMS Training
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In addition, it should be noted that while Colleges and Universities are NOT first response organizations, they are
still an integral component of community. As such, Saint Joseph’s University will train university responders through
courses such as the National Incident Management System (NIMS) and Incident Command System (ICS) or
equivalent.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
9.0 Hazardous Materials Registration Program
The US Department of Transportation requires that any individual, firm, corporation, company, association etc. who,
between July 1 of a year and June 30 of the following year, offers or transports in commerce any of the following
categories of hazardous materials (including hazardous wastes) must register for that twelve-month period:
A highway route controlled quantity of a Class 7 (radioactive) material, as defined in 49 CFR
More than 25 kilograms (55 lbs.) of a Division 1.1, 1.2, or 1.3 (explosive) material (see 49 CFR 173.50) in a motor
vehicle, rail car, or freight container.
More than one liter (1.06 quarts) per package of a “material extremely toxic by inhalation” (that is, a “materials
poisonous by inhalation” (that is, a “material poisonous by inhalation,” as defined in 49 CFR 171.8, that meets the
criteria for “hazard zone A” as specified in 49 CFR 173.116(a) for gases or 173.133(a) for liquids).
A hazardous material (including hazardous wastes) in bulk packaging have a capacity equal to or greater than 13, 248
liters (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids. Please note that
under this provision persons who offer or transport hazardous materials that do not require placarding (that is, Class
9 materials) in a bulk packaging with a capacity greater than 3,500 gallons or 468 cubic feet, must register.
A shipment in other than a bulk packaging of 2,268 kilograms (5,000 pounds) gross weight or more of one class of
hazardous materials (including hazardous wastes) for which placarding of a vehicle, rail car, or freight container is
required for that class.
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The 2006-2009 registration statement and payment has been submitted and will be renewed upon expiration.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
Appendix A: Security Plan Training Certification
I, __________________________________, have read Saint Joseph’s University’s written security risk assessment
and Security Plan and have been trained on its contents. I understand the risks associated with the transportation of
hazardous chemical products and waste as explained in the risk assessment, and I pledge to adhere to the
requirements of the Security Plan while I am employed with, or employed as a subcontractor to, the Saint Joseph’s
University.
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Employee Signature Date
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
Appendix B: Chemical Inventory and Potential Security Risks
Complete Chemical Inventory can be found in the Department of Safety, Health and Environment as well
as Science Center locations. Contact HSE Director at 610 660 3037 for additional information.
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.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
Appendix C: Additional References for SecurityRelated Information
DOT’s Hazardous Materials Safety Webpage: Provides the latest government alerts on terrorism. The website
address is http://hazmat.dot.gov. Information of the RMSEF’s development, structure, and testing can be found at
http://hazmat.dot.gov/rmsef.htm.
Federal Motor Carries Safety Administration Security Talking. Security talking points can be found at the DOT
Federal Motor Carries Safety Administration Website at www.fmcsa.dot.gov/hazmatsecure.htm. The topics include
general security information, personnel security, technical innovations, and management prerogatives.
American Chemistry Council Webpage: Provides guidance on transportation security and guidelines on site security
for chemical plants. The website address is http://www.americanchemistry.com.
Transportation Research Board Security Webpage: Provides links to documents and other information on the
following topics: general transportation security, aviation security, surface transportation security, seaport/maritime
security, and general national security websites. The website address is
http://www4.trb.org/trb/homepage.nsf/web/security.
National Safety Council Webpage: Presents general safety information, including a document entitled “Effective
emergency Response Plans: Anticipate the worst, prepare for the best results.” The website address is
www.nsc.org/issues/emerg/99esc.htm.
• National Cargo Security Council Webpage: Provides theft prevention information, including a list of cargo security
links and the document Guidelines for Cargo Security & Loss Control: How to maximize cargo security on land, air & sea, edited
by Lou Tyska, CPP. The website address is www.cargosecurity.com
American Society for Industrial Security Webpage: Includes security information for industrial facilities, as well as a
document entitled Cargo Theft Prevention: A handbook for logistics security by Louis A Tyska, CPP, and Lawrence J.
Fennelly. The website address is www.asisonline.org.
American Trucking Association (ATA) Webpage: Provides a host of information on government security warnings,
security tips, and other guidance. Available documents include Guidelines for Loss Prevention: Physical security in motor
carrier freight terminals and Security and the Driver, both authored by the Safety & Loss Prevention Management Council.
The ATA website address is www.truckline.com . In addition, ATA hosts CargoTIPS, an interactive cargo theft
information processing system available at www.cargotips.org.
• Agency for Toxic Substances and Disease Registry (ATSDR) Webpage: Provides information on general hazardous
materials emergency response as well as strategies for mitigating and preventing terrorism involving industrial
chemicals. The website address is http://cisat1.isciii.es/. 22
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U.S Environmental Protection Agency (EPA)’s Counter-Terrorism Webpage: Provides publications, links, and alerts
related to EPA’s role in counterterrorism. EPA’s recommendations on chemical accident prevention and site security
can be found at http://www.epa.gov/ceppo/pubs/secale.pdf. The website address is
http://www.epa.gov/ceppo/cntr-ter.html.
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
Department of Defense (DoD) Guidance on Security and Transportation. Although these DoD guidance’s are
written specifically to ensure the security of nuclear, chemical, or conventional weapons during transportation, many
of the practices are easily applicable to the transportation of other high-value loads, including hazardous materials
loads. 1) Physical Security of Sensitive Conventional Arms, Ammunition, and Explosives (D0D 5100.76-M); 2)DoD
Nuclear Weapons Transportation Manual (DoD 4540.5-M); and 3) Physical Security Program (DoD 5200.8-R). The
website address is http://www.dtic.mil/whs/directives.
• National Institute of Justice and Sandia National Laboratories: Provides information on security, terrorism, and
assessment methodologies.
The website addresses are http://www.ojp.usdoj.gov/nij and http://www.sandia.gov.
• NIMS Training. Additional information on this topic can be found at:
http://www.fema.gov/emergency/nims/index.shtm
DOT registration. Additional information can be found at DOT’s website at:
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http://hazmat.dot.gov/regs/register/register.htm
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001
Appendix D: Regulatory References and Reporting Forms
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Regulation 49 CFR 172.01 – full copy available at www.access.gpo.gov
Saint Joseph’s University, Administrative Services Department of Health, Safety and Environmental Compliance SJU DOT
Security Plan HSE-E-001

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