A DOT security plan needs a transportation risk assessment and measures for personnel, access and en route security. It also needs a responsible senior management job title, implementation duties, an employee notification process and a hazmat training plan. 49 CFR 172.802 sets these requirements.
What is the first step?
Write down the security risks of moving your propane, including at any site where a load is filled, stored or unloaded along the way. Then set steps to deal with each risk.
What security areas does paragraph (a) cover?
- Personnel security. Confirm what job applicants tell you before they get jobs that handle the propane, within employment and privacy law.
- Unauthorized access. Keep people who should not be there away from the propane and from trucks being loaded for a trip.
- En route security. Cover the trip from start to finish, including any stop where the load sits along the way.
What else does paragraph (b) require?
Name the senior management person in charge of writing and running the plan by job title. Give security duties to each position or department that carries out the plan. Say how your crew is notified when it is time to implement a part of the plan. Add a hazmat employee training plan: security awareness training for every hazmat employee, and in-depth security training for the people who carry out the plan, under 172.704(a)(4)-(5).
How do we keep it?
Keep the written plan and risk assessment as long as they are in effect. Review them at least annually and update them when things change. Employees who carry out the plan get the current version, or the parts they need, subject to clearance or background restrictions and need-to-know limits. Tell them when it changes. Keep a copy, on paper or as a file, reachable at or through your main office for DOT or DHS officials who ask.
Who needs the plan at all?
See does my propane company need a DOT security plan.
We help with safety manual writing, review and revision; see propane safety help.