US DOT Security Plan for Farmers?
Bruce E. Paulsrud, Extension Specialist, Urbana, 217-244-9646,
Source: Illinois Pesticide Review Vol. 16, No.6
"Persons, including farmers, who ship or transport hazardous
materials in commerce in amounts that require the shipment to
must develop and implement security plans by September 25, 2003.
Examples of materials to which the security plan requirement
applies include explosives such as dynamite or detonators, pesticides,
fertilizers such as anhydrous ammonia or ammonium nitrate, and
fuels such as gasoline, diesel, and propane.
- "If you ship
or transport fertilizers, pesticides, gasoline, diesel fuel,
or propane in packages or containers that are larger
than 119 gallons or the total quantity you ship or transport
at any one time is more than 1,000 pounds, then you must have
a security plan.
- "If your supplier delivers the pesticides,
fertilizers, and fuels you use to your farm, then you do not
need to have
a security plan.
- "If you only transport fertilizers, pesticides,
and fuels between fields of your farm, then you do not need to
have a security
The preceding text is part of a U.S. Department of
Transportation (US DOT) fact sheet (HMR-4922) entitled "Hazardous
Materials Transportation Security Requirements: Applicability
and Farming Operations." This fact sheet was available from
US DOT's Web site earlier this fall, but now it is gone. You're
not alone if you're asking, "Where did all of this come
from, and what happened to the fact sheet?"
The Rest of the Story
On March 25, 2003, the final rule for "Hazardous
Materials: Security Requirements for Offerors and Transporters
Materials" was published in the Federal Register (vol. 68,
no. 57; http://hazmat.dot.gov/rules/68fr-14509.htm). In a nutshell,
the revised regulations require that shippers and carriers must
Have a written security plan in place by September 25, 2003.
Train all HAZMAT employees (any person under your corporate
control who performs any task covered by hazardous materials
regulations) on the written security plan by December 22,
3. Provide all HAZMAT employees with security-awareness
With heightened national security concerns, it is
no surprise that the existing hazardous materials regulations
be reevaluated and modified in some way. What is surprising
is that farmers
appear to have been sucked into the regulations this
time. Or did they? As I understand it, US DOT put the security-plan
for farmers on hold and is discussing the issue with
state departments of transportation, and the American
The Illinois Fertilizer and Chemical Association (IFCA;
has also been active in this arena and sponsored several
workshops across Illinois this summer to help its dealer
US DOT security plans.
At this time, it is not clear
how this regulatory change will affect farmers. Will farmers
need a security plan
to pick up certain pesticides in mini-bulk containers
or anhydrous ammonia tanks from their dealer? These
a few of the
questions that have been raised. In addition, there
are logistical and enforcement questions that need answers.
As this issue
stay tuned by talking with your dealers and farm and