One of the most critical components of rulemaking for the department of transportation1 is the assessment of possible transportation security risks for covered shipments of risky materials. Many companies have implemented numerous security measures without examining the threats against their operations and their vulnerabilities to those threats. Threats are sources of danger and can include both criminals and terrorists and the attacks that they might initiate to achieve their objectives. Vulnerabilities are weaknesses that make us more susceptible to attack or injury.
When conducting a proper assessment of the threats to and vulnerabilities of the operation to a terrorist attack or terrorist activity, the types of information to consider include: (a) the type of risky material to transport, (b) the frequency and quantity of shipments, (c) the packaging type, and (d) the amount stored on-site. It is needed to identify and address the business practices (including relationships with external partners), such as the emergency response information that is available on site, and physical assets that are a part of the hazmat transportation activities.
It is needed to analyze the company's business practices that affect the transportation of the risky materials included in HM-232 to identify potential security vulnerabilities. Such business practices may include:
'Taking and proce...
relate to ensuring the trustworthiness of employees); Job descriptions, organization charts, and reporting structures for responsible management and decision making, security policies, and reporting (which all relate to who has access to information and who makes key decisions); Facility and building access policies and procedures; Qualification and selection of outside service providers (contractors) with access to hazmat handling areas; and Policies and procedures on distributing information related to hazmat shipments, including to business partners.'
It is better to analyze each physical asset (facility, terminal, etc.) used in the transportation of hazmat to identify potential security vulnerabilities. This analysis should consider, at a minimum, the following:
'Exterior surveillance and line-of-sight attack potential; Areas of concealment; Normal and potential vehicle and pedestrian paths; How congestion, choke points (where vehicles or pedestrians may get delayed during an evacuation), and other circumstances might reduce the effectiveness of the security measures; Immediate surroundings - assess the potential for layered protection or and the nature of potential nearby threats; Storage facilities, transfer, loading, and unloading areas; Business offices, storage of empty hazmat packaging; and Visitor, vendor, and employee parking.'
In addition, it is better to examine each configuration of transport vehicles for vulnerabilities based on use and the likely routes. Unlike many facilities, where the areas that are most in need of protection (such as critical operation centers) are separated from an outer fence by a considerable distance, there is no protective buffer surrounding vehicles on the road. Vehicles, therefore, can be more vulnerable. It is also