DOT Security And Hazmat Endorsements

Many of our members have been visited by DOT in the past months and the number one penalty being issued is for the hazmat security program. DOT will show up without advance notice to do a security audit. Even if they have come for another reason, they are mandated to check your security program.

Your security program must cover four elements:

  • Risk Assessment — You must do a risk assessment for your location and then take appropriate measures to address those risks in your written plan.
  • Written Plan — At a minimum, a security plan must include the following elements: 1) personnel security, 2) unauthorized access, 3) en route security.
  • In-depth Training on the Written Plan — Hazmat employees of employers that are required to have a security plan must receive in-depth security training on the security plan and its implementation. In-depth security training must include company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure.
  • Security Awareness Training — Each hazmat employee must receive security awareness training. This training must include an awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security. A component covering how to recognize and respond to possible security threats must be included.

DOT has issued a revised CD that covers the security awareness training very well. The new version allows an employee to sign in, watch the CD to receive the training, take a test, and then print a training document for your file. This CD is available for free at: http://hazmat. dot.gov/riskmgmt/hmt/hmt_security.htm. Completion of this training module and the interactive test will meet the security awareness training requirement.

Important Points to Remember
In reviewing the recent DOT audits on our members, I don’t find DOT penalizing you for what you have in your risk assessment or your written plan because there are very few actual requirements of what you have to cover and include. What they are penalizing for is if you don’t have one of the above four required security elements completed and documented. The typical penalties being issued are averaging between $3,000 and $4,000.

To get a copy of the actual security questions that you will be asked during a review, download the “Guide to Developing an Effective Security Plan for the Highway Transportation of Hazardous Materials” found at this link: http://www. fmcsa.dot.gov/safetyprogs/hm/Security_ Plan_Guide.pdf.

Look at Appendix D for the actual review questions.

HM Endorsement Renewals and Applications
Another area of concern for our members has been the hazmat endorsement for CDL drivers. We recently surveyed our membership for any problems they have had with this area and pretty much confirmed what I had been hearing all along. Some areas of the country have been very fortunate in getting the background checks completed in about two weeks, but many areas are seeing delays running as long as four months. We have had a few applications for the endorsement lost in the system, which turns into a real nightmare. Some members have found that using their Congressional representatives or state trucking associations have helped to expedite the lost applications.

Helpful hint: Go early. When it comes time for your driver to renew their license, they should be going early. When in doubt about the renewal time frame, I suggest going in at least four to six months early. If the driver does not get the background check completed and approval received back, they will not get their hazmat endorsement, which means they cannot drive a placarded load of cylinders.

Another helpful hint from some of the members is to have the hazmat endorsement application filled out before you go in to renew the license. It speeds up the process. For those states using the federal contractor, you can get the application by going online to: http://www.hazprints.com.

If you have any concerns or questions, please contact me.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT & Homeland Security Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at (573) 785-5111 and at mldsafety@hotmail.com.