Environmental Health & Safety

Hazardous Materials Security Plan

January 2010

Scope:

Hazardous Materials

In accordance with the requirements of the United States Department of Transportation (DOT), 49 CFR Subtitle A - Part 15 and 1520, Amherst College has developed and implemented a Hazardous Material Security Plan that includes the Protection of Sensitive Security Information (SSI).

Purpose:

The United States Department of Transportation requires that shippers of Hazardous Materials/Waste maintain and safeguard information specifically identified as "sensitive", as it pertains to the shipping of hazardous materials and waste.

Applicability:

The regulation applied to shippers of hazardous materials and waste, including Amherst College, who ship hazardous materials and waste in quantities that require registration, through the United States Department of Transportation.

Sensitive Security Information:

Is information that is developed or obtained during the shipment of hazardous materials or waste to or from the College that the Department of Transportation has determined would jeopardize the health and safety of the transportation and hazardous waste disposal industry.

The Amherst College Hazardous Material Security Plan and the information considered to be either known or potentially sensitive requires the College to perform the following to safeguard the transportation and appropriate documentation of our hazardous materials and waste.

Components of a Security Plan:

Transportation in commerce of one or more of the following hazardous materials requires that the College develop and adhere to a security plan for hazardous materials that conforms to the requirements of this guideline:

  1. A highway route-controlled quantity of a Class 7 (radioactive) material, as defined in 173.403, in a motor vehicle, rail car, or freight container;
  2. More than 25 kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material in a motor vehicle, rail car, or freight container;
  3. More than one liter (1.06 qt) per package of a material poisonous by inhalation, as defined in 171.8, that meeting the criteria for Hazard Zone A, as specified in 173.116(a) or 173.122(a) of this subchapter;
    • A shipment of a quantity of hazardous materials in a bulk packaging having a capacity equal to or greater that 13,248 L (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids;
  4. A shipment in other than a bulk packaging of 2,268 kg (5,000 pounds) gross weight or more of one class of hazardous materials for which placarding of a vehicle, rail car, or freight container is required
  5. A select agent or toxin regulated by the Centers for Disease Control and Prevention under 42 CFR part 73; or
  6. A quantity of hazardous material that required placarding.

The security plan must include as assessment of possible transportation security risks for shipments of the hazardous materials and appropriate measures to address the assessed risks. At a minimum, a security plan must include the following elements:

Personal security
  1.  Measures to confirm information provided by job applicants hired for positions that involve access to and handling of the hazardous materials covered by the security plan. Such confirmation system must be consistent with applicable Federal and State laws and requirements concerning employment practices and individual privacy.
    1. Unauthorized access. Measures to address the assessed risk that unauthorized persons may gain access to the hazardous materials covered by the security plan or transport conveyances being prepared for transportation of the hazardous materials covered by the security plan.
    2. En route security. Measures to address the assessed security risks of shipments of hazardous materials covered by the security plan en route from origin to destination, including shipments stored incidental to movement.
      • The security plan must be in writing and must be retained for as long as it remains in effect.
      • Copies of the security plan, or portions thereof, must be available to the employees who are responsible for implementing it, consistent with personnel security clearance or background investigation restrictions and a demonstrated need to know.
      • The security plan must be revised and updated as necessary to reflect changing circumstances. When the security plan is updated or revised, all copies of the plan must be maintained as of the date of the most recent revision.

Amherst College must:

Take all reasonable steps to protect "sensitive information" as it pertains to the storage and transportation of our hazardous materials and waste from unauthorized disclosure, therefore

  1. Sensitive documents and other applicable records will be locked or otherwise secured in location accessible to only those employees of the College with direct responsibility for the disposal, storage or transportation of hazardous materials or waste.
  2. Disclosure of Sensitive Security Information will be limited to only those persons having a "need to know".
    • Sensitive Security Information shall be labeled
      • SENSITIVE SECURITY INFORMATION
        1. WARNING: This record contains Sensitive Security Information that is controlled under 49 CFR Parts 15 and 1520
        2. No part of this record may be disclosed to persons without the "need to know" as defined in 49 CFR Parts 15 and and 1520 except with the written permission of the Administration of the Transportation Security Administration or the Secretary of Transportation. Unauthorized released may result in civil penalty or other action.
        3. The above referenced label shall be conspicuously placed at the top of the records and documents with a Distribution Limitation Statement that is placed at the bottom of document front and back covers, titles and each page of the document.
  3. Electronic information and materials shall also be marked in such a way that notifies viewer or listener of the same restrictions referenced above.
  4. Any person without the "need to know" or who was not otherwise authorized by either the Administrator of Transportation Security Administration or the Secretary of Transportation receive a document or record that contains Sensitive Security Information, which is not properly labeled or marked that person shall contact the office of Environmental Health and Safety or the Chemical Hygiene Officer at Amherst College, immediately.
  5. If either the Chemical Hygiene Officer, Environmental Health and Safety Manager or other persons authorized (covered) by same become aware that Sensitive Security Information has been released to "unauthorized" persons, they must promptly report the infraction to the United States Department of Transportation.

If you have any questions, comments or concerns about this policy, please contact the Amherst College Chemical Hygiene Officer or the Environmental Health and Safety Manager.