Sunday, May 8, 2011

PHMSA HAZMAT Security Plan ICR Renewal to OMB

On Friday the Office of Management and Budget (OMB) announced that the Pipeline and Hazardous Materials Safety Administration had submitted a renewal request, without change, for the current information collection request (ICR, OMB # 2137-0612) for Security Plans for shipping Hazardous Materials. This is a routine request to extend the current program.

An interesting entry in the OMB file is that PHMSA estimates the cost of this program to the Federal Government to be $0. As a taxpayer I am usually happy to see the government controlling costs, but I do remember the old adage, something that is ‘free’ is worth what you pay for it.

The reason that this program has no cost to the PHMSA is that organizations are not required to submit their plans for approval or even review. An inspector making a site visit might ask to see the security plan, but, even then, there is no authority for PHMSA to require changes as long as the plan is in existence. On the other hand, PHMSA doesn’t have much in the way of security experts on staff (that would be a TSA responsibility) so even if they had the authority they wouldn’t have the expertise to effectively review the security plans.

I would bet that there are trucking companies and shippers out there who take their hazmat shipping security responsibility seriously and attempt to really do effective security plans; I salute them. For the vast majority of organizations, however, I would bet that if the plans are prepared, they are treated like just another compliance issue. This would result in an EH&S officer (who in many cases will handle all government paperwork) crafting a simple document that is titled ‘Security Plan’ but does not really address security any more effectively than does their chain link fence.

Oh well, no terrorist has yet hijacked a hazmat truck in the United States and turned it into a chemical weapon. Of course, that means that it will never happen.

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