Skolnik

Seeking an exemption from the security training requirements of HM-232 (Hazardous Materials: Security Requirements for Offerors and Transporters of Hazardous Materials) the Dangerous Goods Advisory Council (DGAC) recently received notification from RSPA (Research and Special Projects Administration) for DOT, that they would NOT agree with the request. DGAC asked that employees who repair, modify, recondition or test packagings and perform no other function subject to the requirements of the regulations be excluded from security training. RSPA further stated that everyone involved in the transportation of hazardous materials should be aware of security issues associated with such transport, and that persons who manufacture or repair packagings should be aware of potential sabotage or other actions that could be directed at operations. Security awareness can be tailored to the specific responsibilities of the haz-mat employee and should be commensurate to the security risks that an employee might encounter. To this point, Security Awareness Training must be completed for all those falling into one of the categories as stated above.