HAZMAT by truck: another vulnerability?

Abstract

Tracking sensitive materials carried by truck has been and currently is subject to Federal law, demonstrated by the use of material safety data sheets, (MSDS) and placarding. However, in 2007 when Implementing Recommendations of the 9/11 Commission Act of 2007 (IRCA) was passed which requires tracking tracing, and reporting of hazmat incidents. Yet, it seems that those responsible, particularly the Transportation Security Administration (TSA) have no new examples of these mandates. Furthermore, there seems to be little involvement of the American Trucking Associations (ATA) in promoting the requirements of the IRCA even though hazardous materials generation, storage, control, and transportation by truck are serious components of a hazmat vulnerability in the United States. Congress states that the transport of hazardous materials accounts for at least 18% of total freight tonnage, and there are more than 400,000 large trucks dedicated to its movement. The IRCA called for new information on costs and benefits of utilizing tracking technology for motor carriers transporting security-sensitive materials. Federal funding of $7,000,000 was appropriated for this purpose in each fiscal year 2008, 2009, and 2010. On May 27, 2008 the Transportation Security Administration released its Report complying to the IRCA’s mandate. Although the Report of the HAZMAT Truck Security Pilot (HTSP) was to demonstrate “new information,” it did not. Instead, it demonstrated the ignorance of TSA, and the U.S. Department of Transportation (USDOT) to understand supply chain tracking and security, and the technology currently available in the market. The Pilot was flawed in many aspects. Its major flaws included the definition of the supply chain, itself; the kinds of logistics data available, access to data, accuracy of data, and the communications system needed to monitor and control. The HTSP pilot was quite limited, and bore little resemblance to reality. In every case of the Report’s recommendations, existing technology can obviate the need for unnecessary technology development to meet the recommendations. There is a clear need for another pilot project that involves a real supply chain, major motor carriers, the American Chemical Council (ACC), current available technology, current providers of that technology, and the active support of the ATA with sound government oversight to ensure that the laws it wrote are implemented and followed.