February 1, 2021: Is Your Current Security Plan Really The Right Fit for Your Facility?

If I told you that I could get into your rail facility, would you believe me? Now, that claim may seem a bit brash on my part and a bit extreme, but I think my EOD training in the military would serve me well. After all, to defeat an enemy or any criminal, you must think like one. But that’s not what I want to talk about. Like the SimpliSafe commercial, I want to tell you what will keep you, your facility, and your hazardous materials safe.

So, how would you secure your hazardous materials or valuable goods from criminals? This is not an easy task and you have to rely upon a myriad of partners to ensure your security plan does what you want it to. Does it? Do you really know what you want your security plan to do? Did you know that every security plan needs to be site-specific?  Take a look at the following!

Think about the time taken by the artist! Think of the value of the motor vehicles contained inside this railroad automobile carrier. There is no question this is a breach of security. How would you defeat this breach of security? Could you?

Let’s think of this in terms of the federal regulations and whether they apply here. The only issue is that one of the required markings, the car number, is not completely visible but otherwise, the answer, of course, is no, the artwork is not a violation of any regulation. Security for the valuable merchandise contained within is a commercial problem and not a regulatory one. Do you still want the artist to have access? NO, but HM-232, the security regulations under DOT published in 2003, never considered the value of the goods in a railcar. The regulations only apply to hazardous materials and only certain ones; usually those that can be weaponized, causing harm to an unsuspecting population.

You may already know that the security regulations are found in 49 CFR §172.800
(Click http://bit.ly/ECFRSecurity). These regulations apply to any mode of transportation since all can transport hazardous materials in commerce but our focus here is on rail. Before I continue though, let me say that the railroads do an outstanding job of apprehending criminals every day of the year. The task is overwhelming though as there are thousands of miles of railroad and acres of property to be patrolled by railroad police. Some of the smaller railroads though, simply don’t have the resources to hire security.

Whether police are on the payroll or not however, they simply cannot be everywhere, and it only takes one nefarious person to bide their time and find the weaknesses.
(Click http://bit.ly/STARSWatching).

So, do you have to hire a person to ride on the operating platform of every tank car to get it there safely? Of course not, but there are some simple steps that will make sure that you know when your hazmat car has been tampered with or product has been removed or potentially adulterated.

To ensure your product is safe, consider the following steps.

First, if you are served by a regional or short line railroad carrier, make certain that they have a security plan that complements yours and they have addressed the issues important to you. They might not give you a copy of their plan but make your concerns clear, especially if there is an indication that your cars may have been occupied or defaced. Graffiti or shotgun shells during deer season, drug paraphernalia are giveaways that you have a security issue.

Second, though the regulations do not require car seals, use them on your manway cover, protective housing cover and bottom outlet. To me, it doesn’t make a difference what material they are made from – plastic, wire or steel will do, as long as you know they were broken.
Finally, and this is the biggest issue I have with seals – MAKE ABSOLUTELY CERTAIN WHEN YOUR SEAL IS APPLIED THE ONLY WAY TO REMOVE IT IS TO BREAK IT! You would be surprised at how many times I am able during an audit, to get into a protective housing cover without breaking a seal, even the expensive wire seals.

By the way, if you need seals of any type, visit the STARS Store at:

https://starshazmat.com/starshazmatdepot/product-category/seals/

Enjoy the following photos of what not to do when sealing a rail car and remember, we are your hazardous materials specialists in all modes of transportation, Contact STARS today to see what we can do for you – Joe Connelly

DOT 111A Tank Car – Class 3 (Flammable Liquid) Service

In demonstrating to our client that their seals were not properly applied, rendering them ineffective, we were able to flatten their plastic seal which had been applied to the keeper on the protective housing securement pin, and remove the pin entirely without damaging the plastic seal. We then reinserted the protective housing pin in the opposite direction, again without damaging or breaking it. There would be no evidence that this protective housing had been opened or the product tampered with because the seal was improperly applied.

Please note: these are our client’s cars and we were hired to inspect them. Our client was provided these photos along with training on how to apply the seal to achieve the level of security they expected.

The same basic procedure was also used to remove seals from pressure cars containing Flammable Gas (2.1) in these photos. We were able to remove the seal completely without damaging it, which then allows access into all valves, fittings, and closures. It does not matter if those seals are wire or plastic, as you will see in the following images. What matters is how they are used.

Please note: This procedure was done while the responsible parties were available to observe for training purposes.