The Dangerous Goods Advisory Council (DGAC) has voiced concerns about hazardous materials security requirements proposed by the Research and Special Programs Administration (RSPA) May 2, 2002. In a letter to RSPA, DGAC president, Alan I Roberts, raised issues regarding carrier registration, shipping papers, security plans, and training.
The RSPA proposal (docket number: 02-12064, HM-232) would require motor carriers registered with the agency to maintain a copy of their current registration certificate on each motor vehicle. It also would require shipping papers to include the name and address of the consignor and consignee, and the shipper's Department of Transportation hazmat registration number, if applicable. In addition, shippers and carriers of certain highly hazardous materials would be required to develop and implement security plans, including a training program that incorporates a security component.
DGAC argues that the rules would add several new identification and disclosure requirements to the transportation safety requirements that will accomplish little, if anything, to improve transportation security. "They will, however, result in increased complexity and cost, a significantly greater potential for error, and subsequent delays," Roberts stated in the letter. "In addition, the relatively vague requirements in many other areas, including personnel security and training, while perhaps intended to allow a measure of compliance flexibility, will instead most likely result in misinterpretation, and inadvertent non-compliance."
Another concern of DGAC focuses on cost-implementation if the regulations are approved. DGAC estimates a cost to industry of $500 million, which the organization argues "will result in very limited benefit, none of which would be derived from use of registration numbers, registration certificates, and consignor/consignee names and addresses for security purposes."
To see the letter, visit www.hmac.org.