Tuesday, October 5, 2010 by
The changes made by the Pipeline & Hazardous Material Safety Administration (“PHMSA”) to the hazardous material security plan requirements became effective October 1, 2010. These changes eliminated the need to have a written security plan for many classes of hazardous material, including Classes 1.6, 2.2, 3, 4.1, 6.1, 7, 8 and 9. In addition, those entities with multiple terminal locations that are still required to maintain a security plan must now ensure that the plan is location-specific. Moreover, the security plan must be reviewed at least annually and revised as necessary to reflect changing circumstances. Finally, the new changes require that the security plan identify by job title the senior management official responsible for overall development and implementation of the security plan.