Since September 11, 2001, the U.S. Department of Transportation (USDOT) has worked closely with hazardous materials shippers and carriers, as well as federal, state, and local government agencies, to improve the security of hazardous materials in our nation's transportation system. This article outlines USDOT's new hazardous materials transportation security requirements and is written specifically to alert and inform farmers, a group that has historically been exempt from hazardous materials (HAZMAT) regulations.

Many pesticide educators (including myself) and regulators were caught off guard by this new regulation because it arrived via federal legislative channels that we don't normally watch. Although I had more questions than answers at the time, I addressed this topic in the November 2003 issue of Illinois Pesticide Review. As you will see in upcoming paragraphs, the question "Does this apply to farmers?" has been resolved.

In a nutshell. Beginning September 25, 2003, agricultural producers who ship or transport certain hazardous materials in quantities that require placards must develop and implement a transportation security plan. The hazardous materials and specific trigger quantities are listed on page 3. The written security plan must include measures to address personnel, unauthorized access, and transportation issues. Your security plan will not be collected by state or USDOT offices, but these agencies are authorized to enforce the regulation. Note that if your dealer/supplier delivers the affected pesticides, fertilizers, and fuels to your operation, you do not need a security plan; but the dealer/supplier does. Furthermore, if you transport the affected pesticides, fertilizers, and fuels only between fields of your farm, you do not need a security plan.

The following information was obtained from a USDOT document entitled "Transportation Security Evaluation & Planning for Farmers, Ranchers, & Production Agricultural Operations." This document, along with the 2-page "Hazardous Materials Transportation Security Plan for Agricultural Operations" can be used by farmers as a template to aid in complying with the new HAZMAT regulations. The original documents can be obtained via USDOT's Web site (http://hazmat.dot.gov/pubtrain/AgSecPlan.pdf; 1/13/04).

Background. Farmers, ranchers, and other agricultural operations can better secure the safe transport of hazardous materials, deter terrorist and illegal acts, and reduce their exposure to liability by developing and implementing security plans that conform to USDOT requirements in 49 CFR Part 172, Subpart I. Agricultural operations commonly use many materials that are potential targets for terrorism and illegal activities, including explosives such as dynamite or detonators; certain poisonous pesticides; fertilizers such as anhydrous ammonia and ammonium nitrate; and fuels such as gasoline, diesel, and propane.

To assist agricultural operations in assessing risk and transporting hazardous materials safely, this sample security plan contains three important components-personnel security, unauthorized access, and security while in transit. Most importantly, the plan conforms to USDOT security requirements for persons who offer or transport hazardous materials.

Assessing Your Risk

Explosion and fire. Hazardous materials that are explosive, flammable, or combustible can be used to attack large groups of people, buildings, and critical infrastructure. Examples include explosives and bulk quantities of gasoline, diesel fuel, or propane. In addition, bulk quantities of ammonium nitrate and ammonium nitrate fertilizers can be used to make explosives. For agricultural operations transporting these hazardous materials, the greatest security risk is that a shipment may be highjacked or stolen.

"Toxic by inhalation" hazards (TIH). TIH materials, either as gases or volatile liquids, can be used to attack people in confined spaces such as buildings or subways. Bulk quantities present dangers to large areas and could affect many people. In agriculture, TIH includes the fertilizer anhydrous ammonia. For farmers transporting TIH materials, the greatest security risk is that a shipment may be highjacked, stolen, or attacked while traveling in a populated area.

Poisonous liquids or solids. Materials with oral toxicity (that is, poisonous if consumed) can be used to attack food or drinking-water supplies. Also, liquids that are toxic via inhalation of their vapors can be used to attack groups of people indoors or outdoors. In agriculture, certain pesticides are considered toxic and are labeled by DOT as "Poison." For agricultural operations transporting toxic/poisonous materials, the greatest security risk is a shipment being highjacked, stolen, or illegally released while traveling in a populated or vulnerable infrastructure area.

Which pesticides are affected? As indicated in Table 1, the regulation specifies that only certain quantities of USDOT Division 6.1 pesticides are affected. The Southern Crop Production Association Web site (http://southcrop.org/Ship_Desc/secondpage.htm) provides shipping descriptions for a wide range of pesticides (in various formulations and container sizes); look for the "6.1" in the product description. Your dealer may have a similar list for products commonly used in your area. The most reliable place to find a product's DOT hazard class is in the "Transportation Information" section of that product's Material Safety Data Sheet (MSDS). You can obtain an MSDS from pesticide dealers or label Web sites, such as www.cdms.net/manuf/manuf.asp.

No joke. Rural America and agricultural products may seem unlikely targets for terrorists. However, before September 11, 2001, few considered it likely that two airplanes would be used in a devastating act of terrorism. Inconveniences in modern air travel serve as reminders that we must be vigilant about homeland security. Now is a good time to critically assess the security and safety of your entire operation and take actions to prevent problems.

Pesticide security and safety resources. For more information about this and other HAZMAT regulations, contact the Hazardous Materials Information Center at (800)467-4922 or visit the Hazardous Materials Transportation (HMT) Security Web site (http://hazmat.dot.gov/hmt_security.htm). You can obtain an additional single-page summary of this regulation from USDOT's Web site (http://hazmat.dot.gov/pubtrain/AgSec%20Flyer%20V5.pdf). For help in assessing the security of your pesticide storage area, see www.pesticidesafety.uiuc.edu/facts/storage.html and www.pesticidesafety.uiuc.edu/facts/securityposter.pdf.

(Bruce E. Paulsrud)