CIFMD
INTERPROFESSIONAL
GUIDELINES
CONCERNING CHAPTER 1.10
OF ADR, RID AND ADNR
SECURITY OF THE TRANSPORT
OF DANGEROUS GOODS
BY LAND
15/06/2005
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TABLE OF CONTENTS
PRELIMINARY
page 4
1 – INTRODUCTION
page 5
2 – LEGAL REQUIREMENTS
page 6
3 – ADR CHAPTER 1.10 PROVISIONS
page 7
4 – INTERNAL SECURITY PROCEDURES
page 12
5 – PARTICIPANTS DUTIES AND RESPONSIBILITIES
page 17
6 – RISK ASSESSMENT
page 19
7 – SECURITY MEASURES
page 25
8 –SECURITY PLAN
page 28
9 – PROTECTION OF INDUSTRIAL SITES
page 30
10 – TRAINING
page 31
11 – CONCLUSION
page 33
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Annexes
1-
References and links
2Template (risk evaluation and protective measures) for a
category of transport
3goods
Recommended provisions for the transport of dangerous
4Examples of relevant additional measures
transport of “high consequence” dangerous goods
CIFMD Inter-professional Guidelines – Chapter 1.10 ADR, RID and ADNR – Security DGT
for
the
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PRELIMINARY
CIFMD is an inter-professional association of French shippers and carriers involved in the
transport by road and/or rail of dangerous goods.
The purpose of this guidance document is to provide companies, through their
professional organisations, with methods for evaluating the different security risks they
could face and for selecting the most relevant operating practices to reduce these risks
and facilitate the implementation of the French Government security plan, “Vigipirate”.
Some professional organisations have already developed specific guidelines. Others
might, if necessary, complete this guidance document with measures adapted to their
specific activity.
It is up to the companies concerned to select the elements appropriate to their needs
from the suggested provisions.
This document will be supplemented and updated according to changes1 in legal
requirements and feedback from practical experience.
Scope
Chapter 1.10 being only included in ADR, RID and ADNR, this guide does not cover
marine and air transport security but it is focused on road transport. It could be adapted
to the specifics of rail and inland waterways transport of dangerous goods.
Based on the composition of CIFMD2 (shippers and carriers) these guidelines do not
cover security matters involving the management of transport infrastructures.
It does not deal in details with the protection of loading sites, such dispositions being
encompassed in other regulations.
The SGDN (French Junior Minister’s office of Defence) is working on the subject ; in case of regulatory
changes, the new requirements will, of course, be integrated to the measures implemented by the companies
involved.
2
Shippers : AFGC, AUTF, CFBP, FCCC, SFEPA, UFCC, UFIP, UIC, UIP
Carriers : ATMD, CAF, FNTR, TLF, UNOSTRA and SNCF
1
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1 – INTRODUCTION
ADR 2005 includes Chapter 1.10, introducing new provisions concerning the transport of
dangerous goods.
General measures are applying to the transport of all dangerous goods (1.10.1 and
1.10.2 sections). However, special requirements apply to “high consequence” dangerous
goods (section 1.10.3)
Therefore, according to 1.10.4 section, the requirements of Chapter 1.10 do not apply to
the quantities transported below the levels specified in 1.1.3.6.3 paragraph, whether the
dangerous goods are classified “high consequence” or not.
Chapter 1.10 of ADR 2005 render security measures compulsory for the organisations
involved, but it is rather non managerial as far as the operational practices are
concerned. Unless they are submitted to specific regulations3, the participants in the
transport chain have to decide on their own on the appropriate means to protect against
malevolent actions during the transport of dangerous goods.
In such a context, how can one select the most relevant measures, adapted to each
specific situation, without becoming obsessive over security risks, or, at the other
extreme, without implementing minimalist and rather ineffective measures?
With each transport operation being specific, providing a global response for all
companies involved is not achievable. It is therefore possible to consider different
methods and criteria to be implemented as detailed below.
This guide analyses the provisions applying to transport operations and, separately, the
specific duties of other participants (shippers, consignees, consignors, forwarding
agencies...).
As training is the most important feature to ensure an efficient implementation of the
selected measures, chapter 10 of this guide is devoted to security training provisions, to
be included in the training plans.
3
e.g. explosives or radioactive materials
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2 – LEGAL REQUIREMENTS
The 13th edition of “UN Recommendations for transport of dangerous goods” lists the new
security provisions which have been included, and expanded in regulations applying to
the different modes of transport: road, rail, air, marine...
2.1 Transport modes
The main requirements for road transport are encompassed in Chapter 1.10 of ADR
2005; it comes into effect in the European Community with Directive 2004/111/CE, and,
in France, with the ministerial order, December 20th, 2004, modifying the “ADR” order
dated June 1st, 2001.
Some small changes have been done, mainly in Chapter 1.3 and Chapter 1.8, to take
into account the needs of Chapter 1.10 on provisions concerning the training and
responsibilities of the Transport Advisor.
Some equivalent provisions concerning rail transport are included in the RID Chapter
1.10 (see Directive 2004/110/EC and ministerial order, December 21st, 2004), and to
transport on waterways (see ADN, Chapter 1.10).
In France, Decree # 2004-290 (March 26th, 2004) makes official the “ISPS” Code
(December 12th, 2002) annexed to the “SOLAS” Convention, concerning the security of
marine transport and harbour areas. The requirements in this code apply to goods and
passengers ships. This code draws up provisions for security plans concerning ships and
harbours, as for “high consequence” dangerous goods in the ADR.
The security requirements for air transport are not limited to dangerous goods.
The guidelines hereafter concern mainly ADR and road transport, but they are easily
adaptable to rail or inland waterways transport. Footnotes highlight the specifics of these
modes.
2.2 Specific systems
In most cases, the whole legal requirements concerning the security of dangerous goods
transport are covered by ADR Chapter 1.10 or an equivalent set of rules for other modes.
Therefore, some goods shall meet other legal requirements when in France :
- explosives (decree # 81-972, ministerial orders on March 3rd, 1982)
“sensitive” devices (Defence), Interdepartmental directive June 25th, 1980
- munitions, decree # 95-589
- radioactive materials, ADR and annexes
It is not our purpose to comment on these specific provisions. These measures should be
included in the plans implemented by companies, according to Chapter 1.10.
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3 – ADR CHAPTER 1.10 PROVISIONS
The ADR regulations apply to all transports of dangerous goods (“general provisions”,
section 1.10.1 and “training”, section 1.10.2); additional provisions (1.10.3) apply to “high
consequence” dangerous goods listed in section 1.10.5. According to section 1.10.4,
Chapter 1.10 does not apply to the carriage of quantities below the level in paragraph
1.1.3.6.3.
3.1 General provisions
ADR requirements
1.10.1
General provisions
1.10.1.1
All persons engaged in the carriage of
dangerous goods shall consider the
security requirements for the carriage of
dangerous goods set out in this chapter
commensurate with their responsibilities.
Dangerous goods shall only be offered for
carriage to carriers that have been
appropriately identified.
Areas within temporary storage terminal,
temporary storage sites, vehicles depots,
berthing areas and marshalling yards used
for temporary storage during carriage of
dangerous goods shall be properly
secured, well lit, and where possible and
appropriate, not accessible to general
public.
Each crewmember of a vehicle carrying
dangerous goods shall carry with them
means of identification, which includes
their photograph, during carriage.
Safety inspections, in accordance with
1.8.1 and 7.5.1.1 shall cover appropriate
security measures
The competent authority shall maintain
up-to-date registers of all valid training
certificates for drivers stipulated in 8.2.1
issued by it or any recognized
organisation.
1.10.1.2
1.10.1.3
1.10.1.4
1.10.1.5
1.10.1.6
Comments
General requirements
involved
for
all
persons
It is compulsory to identify the carrier
before loading
Specific provisions for temporary sites.
Does not apply to car parks and other stop
sites where the vehicle is still under the
responsibility of its crew
A driving license meets the rule but other
documents are acceptable
The section 7.5.1 concerns companies only
This is the duty of legal authorities
Note: See Annex 3 for the general provisions in accordance with sections 1.10.1 and
1.10.2, concerning companies, which are not involved in the carriage of “high
consequence” dangerous goods
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3.2 Training
ADR requirements
1.10.2
Security training
1.10.2.1
The training and the refresher training
specified in Chapter 1.3 shall also include
elements of security awareness. The
security refresher training need not be
linked to regulatory changes only.
Security awareness training shall address
the nature of security risks, recognising
security risks, methods to address and
reduce such risk and actions to be taken in
the even of a security breach. It shall
include awareness of security plans (if
appropriate) commensurate with the
responsibilities and duties of individuals
and their part in implementing security
plans.
1.10.2.2
Comments
Security training concerns the drivers as
well
The Transport Safety Advisers (DGSA?)
shall, of course, have the competences in
line with their responsibility
See Chapter 10 hereafter, “Training”
3.3 Specific provisions for “high consequence” dangerous goods :
ADR requirements
Comments
1.10.3
Provisions for high consequence
dangerous goods
1.10.3.1
“High consequence dangerous goods” are
those which have the potential for misuse
in a terrorist incident and which may, as a
result, produce serious consequences,
such as mass casualties or mass
destruction. The list of high consequence
dangerous goods is provided in Table
1.10.5
Security plans
Whether the goods are classified as “high
consequence” or not may not be sufficient
for a correct risk assessment (see Chapter
6)
Carriers,
consignors
and
other
participants specified in 1.4.2 and 1.4.3
engaged in the carriage of high
consequence dangerous goods (see Table
1.10.5) shall adopt, implement and
comply with a security plan that addresses
at least the elements specified in
1.10.3.2.2
Security plans encompass a set of
measures, procedures etc. aiming to
improve the security. To facilitate their
implementation, it is recommended to have
one document called “Security Guidelines”
or “Security Plan”...
1.10.3.2
1.10.3.2.1
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ADR requirements
1.10.3.2.2
a/
b/
c/
d/
e/
f/
g/
The security plan shall comprise at least
the following elements:
Specific allocation of responsibility for
security to competent and qualified
persons with appropriate authority to
carry out their responsibilities;
Records of dangerous goods or types of
dangerous goods concerned
Review of current operations and
assessment of security risks, including
any stops necessary to the transport
operation, the keeping of dangerous
goods in the vehicle, tank or container
before, during or after the journey and the
temporary storage of dangerous goods
during the course of inter-modal transfer
or transhipment between units;
Clear statement of the measures that are
to be taken to reduce security risks,
commensurate with the responsibilities
and duties of the participant, including:
- training,
- security policies (e.g. response to higher
threat conditions, new employee/
employment verification etc.)
- operating practices (e.g. use of known
routes, access to dangerous goods in
temporary storage (as defined in c/,
proximity to vulnerable infrastructure
etc.)
- equipment and resources allocated to
the reduction of security risk
Effective and up to date procedures for
reporting and dealing with security
threats, breaches of security or security
incidents;
procedures for the evaluation and testing
of security plans and procedures for
periodic review and update of the plans ;
measures to ensure the physical security
of transport information contained in the
security plan and
Comments
The duties and responsibilities of every
employee concerned must be precisely
defined
Information has to be correctly distributed 4
This evaluation can only be performed by
the participant at each step of the operation
The critical point is the selection of relevant
measures, adapted to the risk as assessed
at the previous step
Specific training to security plan
The measures to be taken shall be
considered in accordance with the risk
evaluation and level of the French plan
“Vigipirate”
The working relation with competent legal
authorities has to be organised
Periodic tests will be conducted and their
results evaluated
Protection of information concerning the
measures encompassed in the security
plan
.../
4
An exact record of the quantities carried during each operation is not mandatory in security plans but this
information has to be recorded in the transport document ( See 5.4.1) ; a company’s management may decide to
keep this information secret to detect possible theft and security breaches
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ADR requirements
Comments
h/ Measures to ensure that the distribution of Protection of information
information relating to the transport transport operations
operation contained in the security plan is
limited to those who need to have it. Such
measures shall not preclude the provision
of information required elsewhere in
ADR.
related
to
NOTE: Carriers, consignors and consignees should cooperate with each other and with competent authorities
to exchange threat information, apply appropriate
security measures and respond to security incidents
Procedures involving both the participants
and the competent authorities will be
defined to ensure the distribution of
preventive threat information
Devices, equipment or arrangements to
prevent the theft of the vehicle carrying
high consequence dangerous goods (See
Table 1.10.5) or its cargo shall be applied
and measures taken to ensure that these
are operational and effective at all times.
The application of these protective
measures shall not jeopardize emergency
response.
NOTE: When appropriate and already fitted, the use of
transport telemetry or other tracking methods or devices
should be used to monitor the movement of high
consequence dangerous goods
Devices, equipment or arrangements to
prevent theft are part of the security plan.
The selection of the appropriate devices,
equipment or arrangements depends on
the risk evaluation.
1.10.3.3
The tracking of movements is useful only
for the transport of high consequence
dangerous goods (See 6/4)
3.4 Scope
ADR requirements
1.10.4
In accordance with the provisions of
1.1.3.6, the requirements of 1.10.1,
1.10.2, 1.10.3, and 8.1.2.1 (d) do not
apply when the quantities carried in
packages on a transport unit do not
exceed those referred to in 1.1.3.6.3. In
addition, the requirements of 1.10.1,
1.10.2, 1.10.3, and 8.1.2.1 (d) do not
apply when the quantities carried in tanks
or in bulk transport unit do not exceed
those referred to in 1.1.3.6.3.
Comments
The provisions of subsection 1.1.3.6 prevail
on those of Chapter 1.10
Exemption for limited quantities is extended
to bulk and tank transport while the
provisions of subsection 1.1.3.6 usually
apply to quantities carried in packages
only.
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3.5 List of high consequence dangerous goods
Comments
ADR requirements
1.10.5
High consequence dangerous goods are
those listed in the table below and carried
in quantities greater than those indicated
therein.
Possible distinction between the various
dangerous goods classified as “high
consequence” are described in the chapter
“Risk Evaluation” hereafter.
The quantities of subsection 1.1.3.6.3
prevail on those of table 1.10.5
Table 1.10.5
Class
Division
1
1.1
1.2
1.3
1.5
2
3
4.1
4.2
4.3
5.1
6.1
6.2
7
8
a
b
Quantity
Substance or article
Tank (l)
Bulk (kg) Packages (kg)
a
a
Explosives
0
a
a
Explosives
0
a
a
Compatibility Group C Explosives
0
a
Explosives
0
0
a
b
Flammable gases (classification codes
3000
including only the letter F)
a
Toxic gases (classification codes
0
0
including letters T, TF, TC, TO, TFC
or TOC) excluding aerosols
a
b
Flammable liquids of packing groups
3000
I and II
a
a
Desensitized explosives
0
a
a
Desensitized explosives
0
a
b
Packing group I substances
3000
a
b
Packing group I substances
3000
a
b
Oxidizing liquids of packing group I
3000
b
Perchlorates, ammonium nitrate and
3000
3000
ammonium nitrate fertilizers
a
Toxic substances of packing group I
0
0
a
a
Infectious substances of Category A
0
Radioactive material
3000 A1 (special form) or 3000 A2, as
applicable, in Type B or Type C packages
a
b
Corrosive substances of packing
3000
group I
Not relevant
The provisions of 1.10.3 do not apply, whatever the quantity transported
NOTE : For purposes of non-proliferation of nuclear material, the Convention on Physical Protection of
Nuclear Material applies to international transport supported by IAEA INFCIRC/225(Rev.4).
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4 – INTERNAL SECURITY PROCEDURES
4.1 “Security”
The word “security” means “the prevention of malevolent actions and protection against
their effects”, while “safety”5 is related to accidental events. According to ADR Chapter
1.10:
“For the purposes of this Chapter, security means measures or precautions to be taken to
minimise theft or misuse of dangerous goods that may endanger persons, property or the
environment”
4.2 Context
Disseminated terrorist groups and spectacular attacks in several countries have marked
the beginning of the XXIst century (See Annex 1), and contributed to the perception of a
worldwide threat. In such a context, the legal authorities (and public opinion) feel
necessary to reinforce the security measures aiming to reduce the possibilities of theft
and misuse of dangerous goods.
The moment they are involved in the storage or transport of possibly dangerous goods,
regardless of legal requirements, companies cannot do without security provisions6.
Those, which fail to take appropriate actions, could see their image damaged and their
company held responsible for the misuse of the concerned goods.
The new provisions concerning security, encompassed in the UN recommendations and
in the ADR Chapter 1.10, especially the implementation of security plans for the transport
of “high consequence” dangerous goods are a response to a general demand, applying
to the specificities of transporting dangerous goods.
They complete the specific legal requirements applying to different products such as
explosives or nuclear materials, or to different sites (“areas of particular sensitivity”,
Seveso/COMAH sites...), which have already implemented measures to protect against ill
actions.
5
This duality security/safety refers to the French sûreté/sécurité. The translation is now familiar to the
specialists but it may be misunderstood, being not consistent with former expressions. In French, the faux ami
“security/sûreté” and “safety/sécurité” induces lots of misunderstandings and misinterpretations in international
debates. As there is no other word in French, the French still say “sécurisé” and “sécurisation” when the subject
is safety improvement.
6
The purpose of measures implemented by carriers to prevent theft of cargo or vehicles is different from those
applying to dangerous goods because targets are different and the criminals are motivated by money (therefore,
some dangerous goods may be potentially covered by lucrative dealings)
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4.3 Purposes and limits of security procedures
While French judicial precedents get to commit companies to achieve safety results,
companies just have a commitment to take defensive security actions. The fact is private
companies are not authorised to implement protective measures that would be effective
against any type of aggression; moreover, they have no real effective response in case of
a well-organised assault of a military type.
-
Reasonable goals, both for public opinion and governmental bodies could be:
to protect dangerous goods against the risk of theft by individuals
to identify the high exposure situations and select actions to minimise the risks,
though it is not possible to eliminate them altogether
to record and notify quickly any attack, theft and misappropriation to make the
action of the police easier and facilitate further investigations.
The main problem for companies is to find out the “proper” level of measures to be
implemented: it is certainly not possible to apply to every transfer of dangerous goods,
even if classified as “high consequence”, provisions that are as restrictive as those
applying to money or, in some countries, to explosives.
It is quite easy to draw up a range of possible measures to enhance security but it is
more difficult to select from these lists the most appropriate, commensurate with the
situation. This guide suggests a response adapted to each specific situation or, at least, a
method to clarify and justify the selected options.
4.4 Principal types of measures to reduce risks
In order to reduce the risks of security breaches, the main provisions aim to:
 ensure that the employees are aware of security instructions
 strictly limit to the employees concerned the distribution of information related to
storage and movement of dangerous goods and existing security measures
 undertake measures (physical and organisational) to reduce the possibility of
theft, misappropriation or terrorist attacks within areas where dangerous goods
are kept or loaded and during transport
 detect as soon as possible security breaches, alert and collect all relevant
information to make police intervention easier.
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A
g
g
r
e
s
s
i
o
n
Minimise
The
Training
Awareness
Employees
Discretion
Dissemination
Information
Disseminatio
n Measures
Equipment
Activities
Risks
Limit
The
effects
Detection
Alert
4.5 Conditions for successful security procedures
As for security or quality processes, the efficiency of security procedures depends on
previous conditions being fulfilled, especially:
 a clear commitment of the top management, supported by the staff
 consideration of the companies specific needs
 adapted procedures, periodically checked up and updated
 awareness of their obligations by all employees
 promotion and implementation of the policy by a co-ordinator
Other conditions of success are more specific to security, especially those concerning
working relationships with other participants or legal authorities.
See hereafter :
- Commitment of top management and staff
One cannot expect from employees to remain alert, to observe instructions and to report
if the top management does not assert its commitment.
- Considering the special needs of the company
It is necessary to consider these needs before selecting the appropriate measures,
sufficient while not unnecessarily expensive or constraining.
- Checked and updated procedures
Periodic checking of the procedures, of their undertaking, of their relevance, reporting the
dysfunctions and following up their consequences are central to keep the employees
aware and make sure that security measures work effectively.
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- Security awareness of the employees
Individuals involved should consider security awareness as a routine and behave
accordingly in the workplace or at home.7 Initial training and refresher training must insist
on this necessity and provide the relevant information.
- Security Co-ordinator8
The company should appoint a co-ordinator9 with overall responsibility for security and/or
several site-based co-ordinators (or a co-ordination structure). The security co-ordinator
devises security policies, draws up the security plan, controls its implementation and
effectiveness; these responsibilities include
 reviewing products and operations
 identifying the different types of situations, producing the risk evaluation and the
consequent measures appropriate to each situation
 devising the training contents for each level of people involved
 checking that procedures exist, that they are current and workable
 organising and verifying tests, practices, audits...
 analysing incidents and their consequences
 liasing with the police and other bodies involved
- Communication with the other participants
Any dangerous good may induce a risk during its lifetime; it is therefore important that a
consistent approach to safety is used by the different participants (even if they keep it
temporarily). They should therefore communicate
 to evaluate the risks of the product and select the appropriate measures
 to guarantee the security of their interfaces, hard (physical moves) or soft
(information distribution)
 to specify the duties and responsibilities10 of each body involved
 to inform each other in case of dysfunction, incident etc.
- Communication with legal authorities
The police may be brought in either shortly after an alert (intrusive or hijacking attempt) or
after a theft or a theft attempt. Communication with legal authorities is not, for now,
encompassed in the legal texts. It has then to be organised by the management on site.
To make sure that the police intervention is effective in case of an alert, it is necessary
that the conditions of intervention have been prepared with the competent persons
belonging to the local security governmental services. It is critical that the alerts are only
emitted when necessary; it is then necessary to specify the conditions required to trigger
an alert within the company. The legal competent authorities should, as well, organise the
conditions of an appropriate treatment of alerts; if they don’t, companies (or their
employees) will not stay motivated.
Different measures can be operated to facilitate the tracking of theft vehicles (See Annex
3 and 4). Preliminary dialogue is highly desirable to enable the collection of a maximum
of useful data in the event of a theft.
7
It may be useful to consider these criteria when appointing security involved employees and to specify
sanctions as a consequence of important security breaches. These sanctions have to be specified in the internal
policies of the company or in contract of employment.
8
Vigipirate speaks of « Correspondant de défense et de sécurité ». According to this guide, it deals with security
and not safety.
9
The Security co-ordinator can be the Internal Safety Adviser as well, though the adviser’s responsibility covers
only the undertaking of the security plan.
10
Procedures for informing the legal authorities shall be specified, especially in case of loss, when circumstances
and location are unknown
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4.6 Main steps for a security process
To answer the questions brought up by the requirements of chapter 1.10, we suggest the
following steps, which are described in this chapter, sometimes different in order:
Risk assessment, according to the substance involved, the specifics of transport
(quantities, frequency, routes...), activities of the company involved (contractor,
consignor, carrier...) and the possible aggression pattern.
List of measures (of all types) possibly contributing to minimise the risks; factors
for ranking are efficiency and feasibility.
Selection of the most appropriate measures, according to the risk evaluation.
Such measures usually include general provisions that apply to the whole activity of the
concerned company or site, supplemented with more specific measures applying to some
activities or substances.
Implementation of the security plan, with other provisions of Chapter 1-10,
especially 1.10.3.2 that is
 Additional provisions to implement the security plan:
Identification of the participants responsibilities (1.10.3.2(a))
procedures to implement the selected measures, operational practices etc
(1.10.3.2(d))
training of the participants (1.10.2 and 1.103.2(d))
provisions to protect sensitive information (1.103.2(g) and (h))
procedures for the treatment of dysfunctions or breaches, the transmission of alert
to the competent authorities (1.103.2 (e) and Note)
 Provisions for the control (evaluation, tests) and refreshing of the the security plan
(1.10.3.2(f)) :
Substances
Type of transports
Activities
Potential threats
Lists of measures
Professional guidelines
Feasibility, Relevance
…
Risk
evaluation
Selection
of
measures
Control and
update
Security
Plan
Responsibilities
Procedures
Training
Devices
…
These steps are detailed herein.
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5 – PARTICIPANTS DUTIES AND RESPONSIBILITIES
The level of commitment to security of the participants in the transport chain is different
depending on their role : consignor, carrier, manager of a temporary storage area etc.
All of them have to meet the requirements of Chapter 1.10 but the practical measures to
be encompassed in the security plan may be quite different, except for training
requirements (1.10.2 and 1.10.3.2.2 (d)) and protection of information (1.10.3.2.2 (g) and
(h)).
According to the LOTI and the BOSSON law (95-96, February 1st 1995’), the agreed price
shall include the security costs.
5.1 The consignor
The consignor does not face the risks directly and the measures to be taken are limited to
information confidentiality concerning transport (selection and training of the employees,
restricted access to sensitive information...)
The consignor shall ensure that the other participants are provided with the proper
information to evaluate their own risks and that they have implemented the corresponding
security plans. The consignor must distribute the information enabling its partners to
evaluate the risks related with the goods to be transported (See 6.3), prior to the contract
of transport.
If necessary, the consignor can require from the shipper or from the carrier to include
some specific measures in the security plan, e.g. employees training and accreditation,
vehicle devices, and control the effectiveness of such provisions.
Due to confidentiality of information included in security plans, the consignor has no
access to the plans of the other participants; it is thus difficult to verify they are effective
enough and well operated.
5.2 The carrier
The carrier shall provide all information requested from the other participants. For
example, if they consider the risk as high, they may wish to be informed in advance of the
exact arrival time on site for loading or unloading and/or be provided with information for
identification of the crew and the vehicle, or again be informed of incidents, delay, or subcontracting etc.
The carrier is not in charge of risk prevention on loading / unloading11 and temporary
storage areas but must respect the safety and security measures set up by the
management of these sites. The carrier may be informed of such measures through the
loading/unloading procedures but, due to confidentiality, the requirements can be
included in specific documents.
In case of transport by a rented vehicle with driver, the company, which rents the vehicle,
is considered as the carrier. The rental company has just to provide a vehicle with the
appropriate device and a driver instructed in his security role; that may include training to
the security equipment fitted to the vehicle.
11
The carrier shall therefore take in account the situations where the unloading site is not secured (delivery to
private houses for example). If necessary, the carrier should inform the shipper or the consignee of security risks
or insufficient protection conditions on unloading site. The carrier should as well estimate the risks concerning
the temporary storage areas before selecting the routes.
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5.3 The loading site and the consignee
The risks related to the transport of dangerous goods should be preferably analysed to
take into consideration the comprehensive security of the site. Any site where dangerous
goods are kept and subject to misuse or attack should be properly secured and protected
against intrusion and theft. The aim should be to achieve a good level of consistence and
co-ordination between the security plan and the protective measures on site.
The methods of risk assessment or selection of preventive measures developed in these
guidelines usually apply to sites as well as to transport though the criteria may be slightly
different. When loading, checks should take place to ensure that the goods are loaded by
the right carrier, meaning that there is an adapted procedure.
5.4 Manager of temporary storage site
Besides the general provisions dealing with information confidentiality and training, the
requirements of 1.10.1.3 specifically apply. As previously said, a good level of
consistence and co-ordination between the security plan and the protective measures on
site is desirable.
5.5 The “Packing” and “Filling up” companies
Provisions about confidentiality and training apply. As they may act as a shipper or a
consignee, the site has to be protected against malevolent actions. In addition, they
should, more specifically, make sure to implement procedures to minimise the risks of
misusing of the goods or alteration of the content of the elements they make up.
Some participants may act simultaneously as “consignor”, “shipper”, “carrier” when
companies transport their own products but it seems interesting to analyse the risks and
specify measures regarding their different functions, especially concerning the allocation
of responsibilities.
A periodic dialogue between the participants in the transport chain should be organised
to ensure the consistence of the system, particularly concerning the security of
information transmission, the evaluation of “sensitivity” of some goods, incidents and
dysfunctions, detected threats etc. according to the note to 1.10.3.2.2
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6 – RISK ASSESSMENT
It is up to each company to carry out its evaluation (see ADR subsection 1.10.3.2.2),
according to its current practices and activities and to select the appropriate means of
control.
The following sections describe one of the methods from which companies involved can
select the elements, which meet their needs.
6.1 The “Security risk” elements
Whatever the choice for an evaluation method, the security risk is the consequence of
different parameters as for example:
 the different scenarios of assault ( theft of part of the cargo, theft of the vehicle,
suicide-attack...) as well as the climate (international, national or local, level of
“Vigipirate” plan...),
 the type of substances and their potential value for misuse,
 the quantities transported and the frequency of transport,
 the routes, stops ...
These different elements interfere with each other. A suicide attack is of very little risk for
a vehicle transporting desensitised explosives while the same vehicle is highly subject to
theft or hijack since the materials can be transformed into explosives.
Taking into account the main risks includes ranking the danger level so that the most
appropriate means can be devoted to the most dangerous situations that shall be dealt
with in priority.
To “evaluate” this danger, it is suitable to define a range of risks and prioritise the
different risks.
Risks are usually analysed as the result of two components, first the consequences that
might ensue from the event, second the probability of its occurrence. A two-axes system
diagram is designed to rank the risks according to their priorities.
We suggest hereafter a different method, using two parameters; one concerns the
transported goods, namely “sensitivity” and the other is related to the specifics of the
transport operation, namely “vulnerability”.
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6.2 Possible scenarios of attack
Three main types of attacks can be directed against transported12 dangerous goods;
these are the possible scenarios for which the risk has to be evaluated :
 theft of part or total of the goods to be misused, possibly after some
transformation (e.g. oxidizing substances of the class 5.1 converted into
explosives)
 hijack of a loaded vehicle for a subsequent misuse of the cargo (possibly after
some transformation) or for an attack aftermath
 a terrorist attack, aiming to cause important and immediate damage (e.g. assault
with military weapons or suicide-attack against a vehicle transporting explosives
or flammable or toxic gases)
Each of these scenarios has its specifics, regarding the substances, the climate, the
probability or the preventing measures.
a/ theft
The threat of theft concerns most of the dangerous goods (except maybe gases
transported in tanks) but it seems to concern mostly packaged materials whose
acquisition is controlled or closely watched: explosives, radioactive materials, some
noxious or infectious substances...
The main threat is when the vehicle has to stop: loading or unloading operations, parking
on controlled or not controlled areas, and even traffic lights or rail-barriers...
It is the most usual threat from individuals without special skills.
Some simple measures should make the access to the product difficult for nonauthorized persons and highlight that the product has disappeared in a short period of
time.
b/ hijack13
Such a threat concerns all the dangerous goods but some are subject to important risks
(see note 13).
Hijack can occur anywhere, even on main roads14 though it has to be mostly feared of in
remote areas (forests, secluded areas...) and during stops. It therefore requires
organisation and is hardly within individual capability.
Due to the necessity of organisation for criminals, the exposure is higher for frequent
movements and predictable routes.
There are a number of measures to minimise the vulnerability of such movements and to
raise the alert rapidly although it cannot be expected to completely frustrate the criminals
in their attempts.
c/ the terrorist attack
Such a threat concerns the substances able to produce a direct important noxious effect:
explosives, toxic or flammable gases... especially in areas where the damage is of high
consequence: urban areas, gathered people, “sensitive” places like big bridges,
barrages, “Seveso-type” sites...
Such an action can be performed by an individual (unbalanced, fanatic, revengeful...) or
by terrorist groups, well organised and heavily armed.
12
The transport of dangerous goods can offer the opportunity to ill-intentioned people to hijack a vehicle and
enter protected sites to commit theft or attacks. Such threats, which are not specific to the transport of dangerous
goods, will be dealt within the regulations concerning access to the sites and not the security of transport.
See Chapter “Protection of sites”
13
Such a threat is highly improbable concerning rail and rather improbable concerning waterways
14
for example by using false roadblocks ; a special safety device has been implemented in Great-Britain from
June 2004’ using “Dangerous load cards”
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It is extremely difficult to fight terrorist attacks because there are no fully effective
prevention measures, except an appropriate choice of routes and a military escort.
It seems, therefore, that except for crisis periods, the risk in France is limited.
It has to be appreciated that the context may be different according to the situation (local
separatists, hot spots...) and subject to modifications due to local, national or international
climate. The responsible persons shall keep in touch with the competent agencies in the
prefectures and take into account the level of operation of Vigipirate.
6.3 “Sensitivity” of substances
All dangerous goods can cause severe damages and disasters, and some materials,
which are not classified as hazardous, may do so too; therefore, they do not induce the
same risks regarding possible misuse. Table 1.10.5 can be used to assess the
differences of classification level between high consequence dangerous goods.
It may be assumed that most of the explosives as described in the section 1.1 are critical
while fertilizers with less than 80% ammonium nitrate are of less interest (unless they are
transformed); thus it is not possible to make an exhaustive comparison of all the high
consequence dangerous goods because different levels can be selected, even in a single
section of the UN classification.
The companies that put the product on the market, i.e. the consignor or their competent
professional organisations are responsible for the classification of the products in their
specific activity15, based on common sense criteria, e.g.
 availability of the considered product by illicit means ; low-cost wide-spread
products such as fertilisers are subject to “opportunity” theft but they do not really
justify the implementation of an important operation to hijack a cargo or a vehicle.
 hazard of the product: the goods classified in the packing group II are assumed to
be less dangerous than those in the packing group I
 ability of the product to be easily transformed in a high risk substance : UN 1204
(alcoholic solution with less than 1% nitro glycerine) is of no use to thieves or
hijackers despite its classification as “high consequence” because the process to
obtain a substance subject to misuse is complicated. On the other hand, some
other goods that are not classified as “high consequence” may be easily
converted into dangerous products,
 easiness of preservation, splitting up, using : gases and radioactive materials are
difficult to handle, an “effective” use of toxic or infectious substances is not so
easy etc.
 levels of Table 1.10.5 : substances classified as explosives, even desensitised,
toxic products of packing group I and infectious substances A are considered of
higher consequence than the other incriminated substances, with levels “0”
instead of 3000 litres or kg.
A 3-level classification “less sensitive”, “sensitive” and “sensitive +” seems to be relevant.
The goods that are subject to specific security requirements and some substances that
are potentially very dangerous, even in small quantities, could be, for example,
considered as “highly sensitive”.
The products listed in Table 1.10.5 as not being of “high consequence” when transported
in packages (“b” in the column “packages”) could be considered as “less sensitive”.
When organising a transport operation, the consignor shall ensure that all the participants
have been properly informed, no later than during the preliminary investigation of the
Some goods which are not classified as “ high consequence” according to the Table 1.10.5 induce a heavy
risk, e.g. detonators. Due to the type of packaging of detonators the 1.4 S classification could apply
15
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sensitivity level of the concerned goods (law 95-96, dated February 1st, 1995), so that
they are able to evaluate the risk.
6.4 the “vulnerability” of the transport operation
Some criteria can be taken in account, such as:
 the more frequent and predictable a transport operation is, the more vulnerable it
is
 full loads are easier to identify than packages and the quantities transported are
more important, so the risk is more important ; Table 1.10.5 takes partly into
account this criterion as some substances are not considered as “high
consequence” when they are packed and as “high consequence” in bulk or tank
 access to loading and unloading sites, small roads and remote areas (forests...)
are more subject to potential theft or hijacking than main roads but this is not
always true
 on the opposite, a terrorist attack should be feared mainly in urban areas or close
to sensitive spots (nuclear sites, “Séveso” sites, barrages, bridges, tunnels where
the criminals can expect a maximum effect ; the risk is increased in case of
tension between groups or countries
 stops, stops-en-route, whatever they are, create dangerous situations (theft or
aggression)
 local situations or periods can increase the risks in some areas
There are different methods to weight these criteria against one another for a
comprehensive evaluation: grading, summation weighted index or not, two axes systems
etc. This guide does not pretend to recommend a method fitting to every situation.
A 3-level classification seems to be relevant:
 “less vulnerable”, e.g. short distance occasional transport, loading / unloading in
well protected sites or close to a police station ...
 “vulnerable”, usual classification when no specific elements induce another
classification
 “vulnerable +” when the legal authorities require it or due to aggravating
circumstances.
Only the company responsible for the evaluation of vulnerability of the transport operation
can perform it properly.
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6.5 Exposure ranking
We suggest assessing the risk by using a four-level classification16, after an accurate
analysis of the sensitivity of the substance concerned and the vulnerability of the
transport operation.
“Low risk”: e.g. transport of fertilisers and other substances considered as “less
sensitive”, non-predictable transports of packed sensitive goods...
“Medium risk”: transport of most of the “sensitive” goods when there is no special
threat, or transports of “highly sensitive” substances in less exposed conditions
(integrated transport operation, non predictable transport, short distance transport,
transport between well-protected sites etc.)
“High risk”: transport of highly sensitive products such as explosives 1.1 or radioactive
materials
“High +”17: transport of highly sensitive substances when the Vigipirate plan reaches the
red or scarlet level, or in case of identified threats
The table hereunder gives an indication on how to rank the level of exposure of a
transport operation:
"Vulnerability"
Less vulnerable
"Sensitivity"
Vulnerable
Vulnerable +
Sensitive +
Sensitive
Less sensitive
High
Medium
Low
High +
High
Low
Medium
Low
Low
6.6 Risk evaluation review
The main purpose of risk identification and risk evaluation is to help the companies in
their selection of appropriate measures to minimise the risks.
Ideally, each transport operation should be understood to assess its specific risks and
select the best-adapted security measures. In fact, the companies concerned have few
possibilities to implement such procedures; it seems practical to group the different
operations and categorise them, depending on the risk homogeneity, so that measures
adapted to each type can be operated.
16
As said before, other methods of risk evaluation can be used. Therefore, whatever the method is, the result is
usually issued as a ranking of the operation on a pre-defined scale. We do not believe it is relevant to have more
than 4 levels because such an analysis cannot be so precise.
17
Local security agencies usually require specific measures in such a case
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A template18 may help to categorise each transport operation: description (substances,
quantities, type of packaging and vehicle, route etc.), main identified threats and risk
level19.
1 / Previous analysis
PATTERN
CATEGORIES
ACTIVITIES
2 / Risk evaluation for each category
Level of
threat
Product
Sensitivity
Transport
Vulnerability
RISK
EVALUATION
Summary
Sheet
18
See Annex 2. The number of security plans may vary, according to the diversity and complexity of the
transport operations, but it should be strictly limited to avoid complicating internal procedures in the company.
Ten different forms should be the maximum number, even for big companies performing diversified operations.
19
There could be several levels if it is assumed that exposure and adapted measures may vary according to the
threat (Vigipirate....). In such a case, the person responsible for the choice of the level has to be identified and the
procedures for distributing the information in the company are well defined.
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7. SECURITY MEASURES20
The purpose of this step is to define a “clear statement of measures that are to be taken to
reduce security risks” according to 1.10.3.2.2 (d), measures to ensure the protection of
information (1.10.3.2.2 (g) and (h) and provisions concerning vehicle equipment
(1.10.3.3).
As seen before in Chapter 4, there are 4 main types of measures according to their main
goals:
 general awareness and accreditation of the employees
 protection of information
 minimising and reducing the risks of theft, hijack or attacks, for transport and sites
 detection of security breaches, alert and co-operation with the legal authorities to
facilitate their intervention
Different reviews of measures, general or specific, have already been produced by
different bodies (See Annex 1).
See Annex 3 and 4 for a compilation of these lists, for easy reference.
They are not all-inclusive; besides, some measures are relevant to specific activities only.
It is up to the companies or professional associations to complete the list or adapt the
means and measures to their specific needs.
7.1 Measures classification
The main provisions encompassed in Sections 1.10.1 and 1.10.2, applying to all the
movements of dangerous goods identified in Chapter 1.10 are listed in Annex 3 to help
identify the companies which do not deal with “high consequence” dangerous goods.
Other provisions are reviewed in Annex 4. They are classified according to the previous
types (personnel, information...) and prioritised according to the level of risk, to facilitate
the co-ordination with the risk evaluation.
The levels of measures in Annex 4 are consistent with the levels of risks (see 6.5):
“L – Low”: common sense provisions and/or simple devices, though necessitating the
implementation of elaborated procedures
“M – Medium”: provisions with a significant cost impact
“H – High”: costly and restricting measures requiring investment and/or operating
procedures
“H+ - High+”: special short-term requirements21
20
Companies may use other methods to select appropriate means to reduce the assessed risks. The method
developed hereafter is independent of the steps taken to carry out the risk evaluation, as long as the result is
equivalent to the method developed in Chapter 6: 4-level ranking, with 2 upper levels concerning operations
dealing with products highly subject to aggressions, with aggravating circumstances.
21
Such measures are usually required by public authorities
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7.2 Selection of measures, adapted to each category
The guidelines suggest the following steps to select the appropriate measures
corresponding to the category types of transport defined in Section 6.6:
 adopt the main provisions ( including Annex 3) applying to the levels of risks lower
than the risk of the concerned pattern- category, provided that they are relevant and
not invalidated by more restricting measures
 select, from the measures of the concerned category, the means commensurate to
the activities of the company and the identified threats
 examine the upper level measures ; adopt these measures which are well adapted to
the operation under consideration without being too expensive or restrictive
 check that all the requirements of Chapter 1.1022 are met and that the main points
identified in the risk assessment process have been dealt with. If they have not, it is
necessary to complete the provisions
Afterwards, it may be useful to fill the pattern category form described in Section 6.6, by
listing the specific measures implemented to reduce the risks, and possibly the measures
to be implemented in case of aggravated threat; having all the information on the same
form makes the evaluation and update of security plans easier (1.2.3.2.2 (f)).
To makes things simple, companies could as well identify the operation with the
maximum level of risk and apply the necessary security measures to their other activities.
7.3 Synthesis of measures
Such a selection of options results from an analysis. To enable an effective
implementation of these measures within the company or site, it is desirable to
differentiate between
 the general provisions applying to all the situations within the company
 the additional measures, specific for a pattern-category, possibly prioritised
according to the evolution of the threat
The employees involved in each operating practice shall be identified, and the
responsible for its application as well and a procedure of implementation and/or control
shall be developed.
22
And other texts that could apply
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MEASURES
Annex 3
Evaluation of
risks
Pattern
category
Annex 4
Level L
Adopt if relevant
Annex 4
Level M
Annex 4
Level H
Select the most
adapted
measures
Check if some measures can
be adopted without being
exceedingly restrictive
Category B
Category A
Level "M"
Category A
Measures
Selection of measures adapted to category A
GENERAL PROVISIONS
FOR THE COMPANY
Additional
measures when
aggravated threat
Specific measures category X
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8 – SECURITY PLAN
To meet the requirements of ADR Chapter 1-10, the security plan shall include, besides
the risk evaluation and a description of the measures selected by the management as
suggested in the previous chapters, some additional provisions either to facilitate the
development of the plan or to ensure its control and update.
The structure for the document is not compulsory; the plan may be limited to a list of
documents and procedures or incorporate additional relevant elements.
Referring to the sections a) to h) of the subsection 1.10.3.2.2, the security plan should
include the following elements24 :
a/ list of people responsible for the management of security issues
Such a provision follows the same procedure than the one used for the definition of
responsibilities within companies.
The following points should therefore be respected:
- appoint a security co-ordinator to implement and control the application of the security
plan
- specify the different responsibilities and duties (consignor, shipping site, carrier...)
within the company
- specify individual responsibility
- check that the employees involved have been properly trained according to Chapter
1.10.3 and subsection 1.10.2 and that they have the required competence and
authority
- clearly formulate the security duties in the job description
b/ list of dangerous goods
This has been done already when evaluating the risk exposure (see 6.3)
c/ evaluation of routine operations and security risk
This review has been done already (see 6.6)
d/ clear description of measures...
This is a review of the step “selection of adapted measures” (see 7.3) including the
provisions concerning the equipment of vehicles (see 1.10.3.3).
Training will be described hereafter
e/ alert procedures for threats and incidents
- it is necessary to define the information distribution : participants in the transport
chain, internal and external information
- The details of triggering an alert and the transmission of information to legal
authorities should be discussed with them, especially for the transport of high risk or
high + risk substances and the details recorded in written procedures
- the individuals authorised to start an alert shall be identified. Contact shall be kept
with at least one of the authorised individuals
- the employees involved shall have written instructions on actions to be taken in case
of incident, whom to inform etc.
24
Or a reference to documents and procedures dealing with the subject
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f/ procedures for evaluation, control, monitoring, update...
A comprehensive plan should include procedures for controlling and updating its
provisions. It is recommended to :
- spot check how the instructions are observed, how the lists and other registration
forms are kept ...
- organise tests to verify the relevance of problems and reactions of the employees...
- organise audits on posts, sites ... at regular intervals
- systematically follow-up the results of controls, tests, audits, incidents, to improve the
operational procedures if necessary
- re-examine the security plan if the activities of the company or the context of the
threat change
- review the plan at regular intervals
According to the evaluation of its own risks, each company has to decide on the scope
and frequency of controls. It is, of course, essential, to keep records of these controls, as
well as of the follow-up of incidents and developments of the security plan.
g/ and h/ measures to ensure physical security and secrecy of information
Provisions of the security plan are encompassed in a document called “Security Plan” or
“Security Guidelines”.
This document is strictly confidential and its access is limited, on the basis of “need to
know”. Appropriate measures shall be taken, especially if the plan is computerised.
The information should not be disseminated to other participants (customers, suppliers),
but it shall be distributed to the administration concerned. Therefore, some sections of
the plan could be available to vetted employees of participants and administrations, to
verify that legal or contractual requirements are fulfilled.
See in Chapter 7 and Annexes 3 and 4 “Information transmission and confidentiality”
NOTE: Carriers, consignors and consignees should co-operate with each other
and with competent authorities to exchange threat information, apply appropriate
security measures and respond to security incidents.
The importance of such a co-operation has been mentioned previously; it is difficult to put
it into practice and make it effective.
It is recommended to avoid working with companies refusing to provide information
considered as relevant.
When “high” risks are identified, the competent authorities should be informed; it is
necessary to discuss the problem and have formal alert procedures (whom alerts whom,
when and what procedures to follow to ensure it is not a false alarm, which information to
provide etc.)
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9 – PROTECTION OF INDUSTRIAL SITES
The managers of sites (shippers, consignees, managers of forwarding platforms...)
should consider the dangerous goods loaded on vehicles AND those stored in depots,
tanks etc. in production and/or storage areas. Security should be assessed specifically,
and not only for transport.
Many companies have already implemented more or less elaborated protection systems
(fencing, guarding, access controlling...). Security plans should be integrated in these
provisions. It would be inefficient and even potentially damaging to separate
responsibilities or to adopt measures applying only to transport operations.
This item is not developed any further in this guide, as it is not included in ADR Chapter
1.10.
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10 – TRAINING
10.1 Legal requirements
With respect to the training of “persons involved in the carriage of dangerous goods” section
1.3.1 of ADR 2005 specifies that: ”training requirement specific to security of dangerous
goods in Chapter 1.10 shall also be addressed”
Subsection 1.10.2 of Chapter 1.10 specifies, “the training and the refresher training specified
in Chapter 1.3 shall also include elements of security awareness”. Paragraph d/ of 1.10.3.2.2
specifies that training procedures shall be included in the measures taken in the security
plan to minimise the risks.
According to subsection 1.10.2.2:
“Security awareness training shall address the nature of security risks, recognising security risks,
methods to address and reduce such risks and actions to be taken in the event of a security breach.
It shall include awareness of security plan (if appropriate) commensurate with responsibilities
and duties of individuals and their part in implementing security plans”.
All the employees involved in the transport of dangerous goods shall, at least, have
training in “security awareness” complemented by specific training as required by their
duties. General security awareness training is appropriate in addition to initial and
refresher training for drivers.
10.2 Security awareness
The goal is to have all the participants concerned with security, considering it as a part of
daily routine in the same way as safety, for example.
It will emphasise behaviour routines to adopt.
The general security awareness training could comprise the following elements:
- a review of possible misuses of dangerous goods world-wide, with examples of
terrorist attacks and other similar examples
- examples of theft and hijacks during transport or loading/unloading operations (such
examples are available in France)
- using these examples, a short description of the main threats and their specificities
(targets, circumstances...), a list of the main points requiring special vigilance and of
different measures to minimise the risks
- a more complete review of individual behaviours to adopt : vigilance, discretion,
respect of instructions, reporting of dysfunctions ...
- a brief survey of the ADR security provisions (“high consequence” dangerous goods,
security plan...).
The drivers should have additional training:
- a detailed review of dangerous situations possible during transport : stops, urban or
secluded areas,
- a detailed review of permanent requirements such as :
o have photo ID passes at all times
o check the vehicle safety equipment before departure
o inform the loading/unloading site of the time scheduling for transport
o communicate in case of delay, incident etc.
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o
o
o
o
o
o
o
allow no unauthorised persons on board (especially hitch-hikers), except if
there is authorisation from the management
lock the cab doors when driving ; lock the cab doors and windows before
stopping in urban areas
do not stop in secluded places
stop preferably in well-lit guarded places
watch out for suspicious behaviour (vehicle following, individuals coming
close when the vehicle stops)
always lock the cab doors and windows before leaving the vehicle, switch on
the alarms, blockers and other equipment
avoid leaving the vehicle unguarded (See Chapter 8.4)
Drivers should be instructed that the respect of such provisions is important for their
personal safety.
A session on security awareness should be included in the basic refresher course
and focus mainly on:
- recent attacks and/or hijacks
- individual behaviours to adopt (again)
When specific risks are identified (especially “Class 1” and “Class 7”), the initial and
refresher training course could include a session on these specific risks, additional
requirements and well-adapted specific measures to minimise them. Such training may
be included in the additional training specific to some activities.
10.3 Tailored training adapted to different functions
Due to the different situations, it is, of course, not possible to detail the tailored training
for each employee, including drivers.
The needs will be thus evaluated individually.
In addition to the basic security awareness training, some subjects will be included as:
- a general survey of the company activities and the goods transported
- an identification of the main risks, in line with the duties and responsibilities of the
employee, as analysed during the risk evaluation
- detailed information on his/her function’s responsibilities’ remit, the persons to inform
in case of dysfunction...
- detailed instructions and procedures to follow, on safety equipment to use and
behaviour in case of incident, theft or aggression should be included in the training.
When the function is sensitive, it is essential to refresh security awareness by focussing
specifically on the right behaviour, the vigilance, the respect of instructions and, if
necessary, the security equipment.
A “Security handbook” including comments, being periodically updated will be useful for
the drivers when taking up the job.
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11- CONCLUSION
In such a climate of threat, all the companies, which are keeping dangerous goods,
should take measures to minimise the risks of theft, hijack or attacks of these goods, let it
be on storage sites or during the transport.
The requirements of Chapter 1.10 of ADR outline the implementation of the measures for
the transport of dangerous goods, leaving the participants free to select the best
operating practices for their activities.
The chapters above provide elements to help companies in the assessment of risks and
the choice of effective means to reduce them.
Protection against malevolent actions is part of the normal duties of a company. All the
employees must be involved in security in the way as they are with respect to safety.
If the commitment of the management is not strong enough, the employees will not
support the security program and maintain the vigilance necessary to implement effective
measures.
Regarding other participants, competent authorities and police forces, co-ordination of
actions and effective distribution of information are critical to ensure continuity in applying
the security policy.
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Annex 1
REFERENCES AND LINKS
Legal texts
 - UN Recommendations for the transport of dangerous goods, 13rd edition
Road Transport
 - ADR 2005
 - Directive 2004/111/EC
 - Ministerial order dated December 20th, 2004, modifying the "ADR" order dated June 1st, 2001
Rail transport
 - RID Agreement, 2005
 - Directive 2004/110/EC
 - Ministerial order dated December 21st, 2004, modifying the "RID" order dated June 5th, 2001
Marine transport
 - Decree # 2004-290 dated March 26th, 2004 in application in France of the ISPS Code, annexed
to the Solas Convention
Specific systems
 Decree # 81-972 and order dated March 3rd, 1982 (surveillance of the transport of explosives)
 Decree # 90-153 d order dated April 27th, 1999 (surveillance of the sites of explosives)
 Interministerial order, dated June 25th, 1980 (transport of « sensitive matierials » for the Ministry of
Defence)
 Decree # 95-589 (munitions)
Surveillance
 Decree # 96-926 (videosurveillance)
 Decree # 2002-539 (remote surveillance)
 Decree # 2002-424 (confidentiality of personal data)
Professional guides
 "Guidelines for transportation security" – CEFIC, EPCA, ECTA – December, 2003
 Guide sur le transport des fertilisants au nitrate d’ammonium en vrac (bulk ammonium nitrate) UNIFA – November, 2004
 Guide professionnel sur la sûreté des transports de GPL – CFBP – January, 2005
 "Industry guidelines for the security of the transport of dangerous goods by road" – document
"INDA" CEFIC, ECTA, CLECAT, FIATA, IRU … – April, 2005
 Recommandations pour la mise en place des dispositions de sûreté dans le transport de
marchandises dangereuses– AFGC – May, 2005
Others
 Protection, sécurité des personnes et des biens sur sites contre la malveillance – brochure n°
5721 des JO - 2000 –GPEM/ME
 "Consolidated guidance for the security of dangerous goods by road" – Dept. of Transport UK and
British professional associations of manufacturers and shippers, March, 2004
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Websites
 http://www.unece.org/trans/danger/danger.htm : transport international legal rules
 http://www.legifrance.org : transport French legal rules
 http://www.transports.equipement.gouv.fr: French Ministry of Transports, transport of
dangerous goods
 http://www.cefic.org : CEFIC site
CIFMD
14 rue de la République, Bat le Diamant A 92909 Paris la Défense
Tel : 01.46.53.10.51 / Fax : 01.46.53.11.03 /
email : contact@cifmd.fr / Site internet : www.cifmd.fr
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Annex 1
TEMPLATE (RISK EVALUATION AND PROTECTIVE
MEASURES)
FOR A GIVEN CATEGORY OF TRANSPORT
A / Description of the category
Company
:
So 1 So Ltd
Site
:
Anywhere
Activity
:
intersites transport, shipped by the product manufacturer
Goods
:
Transport
:
Flammable liquids
Packing Group I
Example # UN 2749, tetramethylsilane
“sensitive” product
Vehicles-Tanks
Industrial site to industrial site, industrial area
No stop – regular pattern, day and hour
Urban area
B / Risk evaluation
Product sensitivity :
may cause violent fire or explosion
Transport vulnerability : low risk when loading / unloading (secured sites), no stop
on the opposite regular pattern, urban area
 Medium vulnerability
Identified threats :
products uneasy to handle  low risk of theft
Attack in urban area or highjacking to commit further attacks
 Low risk, except if the level of alert is high
Global evaluation :
Medium risk under normal circumstances
High risk in case of reinforced alert
C / Protective measures
In addition to the general provisions of the company
- information to the loading and unloading sites of the vehicle, crew and time
scheduling
- means of communication on board
etc.
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Annex 3
RECOMMENDED OPERATING PRACTICES
FOR THE TRANSPORT OF DANGEROUS GOODS
The following provisions should be adopted for all the transports of dangerous goods
(“high consequence” or not), Chapter 1.107, Sections 1.10.1 and 1.10.2
1 / Personnel
All the employees concerned by Chapter 1.3 shall receive initial and refresher training
about security awareness
It is critical that the personnel is reliable and responsible, to ensure an effective
implementation of protective measures. This training is then essential.
According to Subsection 1.10.2.2, this training shall concern the possible misuse of the
dangerous goods and the possible threats during the transport operations.
The following measures will be emphasised:
- vigilance to detect threats and dysfunctions
- respect of legal rules and internal procedures
- confidentiality of security information, activities, routes, time scheduling, protective
measures against theft, procedures for alert
Procedures for appointing and posting people will take into account the security aspects.
2 / Protection of information
Ill-intentioned people try to obtain information about movements of products and related
protective measures. Such information shall then be distributed on a need-to-know basis,
in order to limit a possible dissemination:
- make the personnel aware of the problem of confidentiality
- limit the distribution of documents to the employees needing to have them
- keep the documents in a safe place
- have a security policy for IT
3 / Alert
It is important to rapidly detect and report thefts, hijacks, aggressions, so that the police
force can intervene quickly.
7
According to 1.10.4, provisions of Sections 1.10.1, 1.10.2 and 1.10.3 do not apply to the movement of
products transported in quantities lower than the quantities referred to in 1.1.3.6.3, package, bulk or tank,
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4 / Transports
4-1 Offer for carriage
“Dangerous goods shall only be offered for carriage to carriers that have been appropriately
identified” (1.10.1.2) and, “Safety inspections in accordance with 1.8.1 and 7.5.1.1 shall cover
appropriate security measures”: the responsible person in the loading site shall check,
before the loading operations, that the carrier is appropriately identified. A record of this
check will be kept long enough, to be used in case of incident.
4-2 Crew
The drivers shall receive initial and refresher training on security awareness. They should
know how to use the security equipment fitted to the vehicle.
They shall be informed of the security provisions, with comments and refresher training.
They can be given a driver’s handbook covering security measures.
The drivers of vehicles transporting dangerous goods should meet the following
requirements, providing they are relevant and realistic for their activity.
General provisions
- have an ID pass with photo, at all times (See 1.10.1.4)
- maintain vigilance to detect any dysfunction
- inform quickly the management of any incident
- keep any information concerning products, routes and time scheduling confidential
Before departure
- fill up before departure to avoid stops
- check security equipment, if any
During the transport
- lock the cab doors
- do not accept unauthorised person(s) in the cab without authorisation from the
management
- select routes avoiding urban areas
- communicate any delay, incident or changes
Stops – Parking
- do not stop if not necessary
- when leaving the vehicle, take the keys
- switch on immobilisers if any
- switch on alarms, if any
- lock the windows and doors
- inspect the vehicle before departing
- in case of temporary parking, use secured sites if possible (1.10.1.3)
Incidents – alerts
- inform the management of any detected dysfunction
- in case of attack, never put oneself at risk in an attempt to protect the load
- undertake the procedure
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5 / Protection of industrial sites
Such protective measures aim to prevent ill-intentioned people to easily access to
loading/unloading sites or temporary storage sites. These measures should be general
enough and not related only to the transport of dangerous goods.
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Annex 4
EXAMPLES OF ADDITIONAL MEASURES
RELEVANT TO THE TRANSPORT OF
“HIGH CONSEQUENCE” DANGEROUS GOODS
In addition to the provisions of Annex 3, these measures can apply to the transport of
“high consequence” dangerous goods.
It is the responsibility of the companies concerned to select means in line with the risk
evaluation, according to their activity. Many suggested measures apply only to certain
types of transport or goods.
Due to the different situations, these lists are not all-inclusive and other means to
minimise the risks can be implemented.
The following measures are classified according to the levels of Chapter 7: L – Low; M –
Medium; H – High; H+ - High +;
Each company will decide on periodicity and durability of the suggested measures.
1/ General provisions
1-1 Personnel
Employment, posting and training shall take into account the security aspect of the job.
1.1.1
Recruiting and posting28
(L)
- verify references
- check all the documents presented by the candidate, compare the dates etc.
- consider having a well structured interview to evaluate the personality of the applicant
and validate the information
(M)
- ask for a police record (in France, # 3) where this is allowed by law
- if possible, do not appoint temporary personnel for remote posts without having the
same pre-employment screening or without specific agreement with the contractors
or employment agency to be sure that the personnel meet the criteria.
(H)
- allocate sensitive posts to existing employees
28
Some regulations require in addition an accreditation or an agreement by Prefecture to access to specific
functions
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1.1.2
Actions
(L)
- periodically focus on security awareness
(M)
- check normally that instructions are observed
(H)
- practice tests to evaluate the reactions of employees and relevance of means and
procedures
1.2 Protection of information
(L)
- keep all documents with critical information (time scheduling, routes, protective
means and equipment, alarm, guarding and surveillance procedures...) in locked up
stores or rooms
- before giving any information about security of activities or security plan by phone,
ascertain the identity of the caller
(H)
- distribute information only to individuals vetted by the company in touch
(H+)
- for electronic transmission, use secured networks, specific protocols, access codes,
identification procedures...
1.3 Alerts
(L)
- draw up and implement the procedures of alerts to the authorities, detailing the
decision criteria, the authorised persons with their details, the details of other
participants to inform (principals...), the actions to take, e.g.
o collecting information about the location, vehicle29, cargo
o confirming exactly where and when the product or vehicle was last seen
o reporting these details to the police
o noting the incident number
o reporting to the insurers
- report additional information to the police as soon as possible
- keep this information safe
- inform of the theft the drivers of the company and of other companies so that they can
help in searching the vehicle/cargo
(H)
- co-operate with the legal competent authorities to implement specific procedures for
alert in case of aggression on site or hijack
- consider specific procedures in case of aggression or hijacks with hostage-taking
29
The companies should have records of the vehicles, with photo if possible
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2/ Consignor
The consignor shall provide the carrier with all the information relevant to draw up a
security plan, with a correct risk assessment.
2.1 Choice of the carrier
(L)
- consider having a list of carriers whose operational practices have been verified
- select carriers with Quality Certification30 ; it guarantees the rigour necessary to draw
up and implement a security plan
(M)
- select carriers respecting the professional “good practices” guidelines, if any
2.2 Contract Clause
It is possible to establish that the carrier will meet the same requirements than the
company giving the order, by following the methods: e.g.
(L)
check that the employees have valid appropriate documents31
inform the consignor (the shipping site and the consignee as well) of any
subcontracting
- check that the subcontractor meets the same rules than the user company
-
(M)
- name a “Defence and Security contact”, individual or service32
- verify the criminal record of employees
- spot check that the security contract clauses are observed
(H)
- employ people having been in the firm for a long time
- ask for recent photos (drivers and escorts)
- inform the loading site and the consignee of the vehicle type, model and identification
number, and of the time scheduling for loading/unloading
- inform the loading site and the consignee of the details concerning the driver and the
escort, if any
- have secured procedures for distributing information
- have initial and follow-up audits of the measures of the security plan and their
implementation33
- no subcontracting without authorisation from the consignor
30
For some transports, it is a requirement of ADR
Beware of not fixing too restrictive rules (to cover up for possible mistakes); such rules, being impossible to
meet, could induce onerous extra-costs and a decrease in the offer, with long-term damaging consequences
32
« Correspondant de Défense et de Sécurité », Vigipirate says ; see note 5
33
the security plan being confidential, it should not be given as a whole to customers or other participants
31
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3/ Transport
3.1 Vehicle equipment34
-
(L)
keep the keys in a secure place and have a system to monitor them
have a communication system on board
(M)
- buy vehicles equipped with anti-theft and alarm systems
- have identification systems such as tracking systems
(H)
- use roof marking to help airborne enforcement officers to identify the stolen or
hijacked vehicle
- use alarm systems on the trailer, tank or container (fitted on the doors or inside the
load compartment)
- use alarm systems connected to a security service provider
- have an alarm-button in the cab, to be switched on under constraint in case of
emergency35
- have a system to locate the vehicle in case of alarm, such as GPS or GSM for new
vehicles
-
(H+)
locate the vehicle during the journey ; some vehicles are equipped with an automatic
alarm if the vehicle does not follow the intended route
3.2 Crew
(L)
follow the intended route
inform the management of any unexpected stop, delay, change of route
inform the loading/unloading site if the time scheduling cannot be respected (or
arrange for your office to do so)
- switch on the security devices (blockers, alarms etc.)
-
(M)
- avoid leaving the vehicle unattended
- use preferably well lit and/or guarded parking facilities
- inform the management of the location of the vehicle
- lock all doors while sleeping in the car, except if the vehicle is equipped with alarms
or the facility guarded
(H+)
- 2 persons on board36
- escort
- convoy
34
the company should decide on fitting all of its vehicles with such equipment or only the new ones. It should be
periodically checked that the equipment is in good working order and the drivers trained to use them.
35
different devices exist, enabling the crew to raise the alarm while under constraint
36
mandatory for some transports
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4/ Protection of industrial sites
The purposes are first to delay a possible access to products and then to detect any
attempt of intrusion, so that the responsible persons can be alerted. The measures to be
implemented will restrict access to the site (perimeter and gates) and/or protect the
storage area, using alarms or surveillance equipment.
The managers in charge of security can refer to the document “INDUSTRY GUIDELINES
FOR THE SECURITY OF THE TRANSPORT OF DANGEROUS GOODS BY ROAD”
and to the brochure # 5721, Journaux Officiels “Protection, sécurité des personnes et
des biens sur sites contre la malveillance” though the purpose of this document is quite
different ; it deals with malevolence against public sites, and not specifically against
dangerous goods.
Many companies offer services for implementing protective measures and surveillance of
sites, industrial or not.
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