Gefahrguttransporte – Sicherung & Zwischenfälle Transport of ...

Safety regulations- some first experiences and new developments
Chemical Transport Safety – 2008
29 - 30 September 2008, FCIÖ, Vienna
Christoph Thiel, Bayer Business Services, D-51368 Leverkusen
Translation: Original in German
The terrorist attack on the World Trade Centre in New York on 11 September 2001 has led to many
changes world-wide. Among the activities initiated in its wake were many that aimed at more safety in
the carriage of goods. The risk that hazardous goods in transit may be diverted for use in terrorist
attacks is obvious. The attack on a synagogue in Djerba, Tunesia (2002) highlighted the potential
danger. The internationally organised laws and regulations governing the carriage of dangerous goods
provide a sound platform for exerting global influence and taking effective safety precautions. Chapter
1.4 of the UN Model Regulations includes new rules for more security. In the European region,
Chapter 1.4 was incorporated into ADR, RID and ADNR (soon-to-be ADN) regulations as Chapter
1.10. Beside regulations, voluntary partner programmes such as C-TPAT are playing an increasingly
important role. The ISPS Code, on the other hand, is of relevance only for maritime transport.
Chapter 1.10 has been in effect for three years. Among its key rules are driver identity checks, access
control as well as entry and exit controls e.g. from chemical companies’ premises. Apart from training,
the establishment of a safety plan has been an important new aspect. It has quickly emerged that
many time-tested procedures and methods already exist that meet the requirements of the new
regulations. For chemical companies it is standard practice to have production facilities, loading points
and warehouses on secure plant premises. Access of people and goods to such premises has been
controlled for decades. Logistics services providers are selected carefully, with key criteria including
not only price but also identity and reliability. Chapter 1.10 created need for action, particularly with
regard to the preparation of a safety plan. At Bayer-Holding, responsibility in this regard rests with subgroups
and service entities. The proposed model safety plan has been used by them for guidance,
with own contents added as necessary to adjust it to their specific circumstances. A good case in point
is the VCI Security Recommendations (Security Leitfaden des VCI). As developments continue,
questions arise for all parties concerned: Have there been any changes over the past three years?
Have acquisitions or divestments been made or have there been changes in the entity’s infrastructure
and processes? Has the production of high consequence dangerous goods (HCDG) increased? All
this might have an impact on the security plan. The time has certainly come for an update. The new
guideline issued by the German Federal Ministry of Economics defines who has to be subjected to a
security check under the German Security Clearance Check Act (Sicherheitsüberprüfungsgesetz,
SÜG) and the Ordinance on the Determination of the Scope for Security Checks
(Sicherheitsüberprüfungsfeststellungsverordnung, SÜFG). It is primarily those who are responsible for
drawing up the security plan and those who have access to the complete security plan. Contact your
associations to find our whether similar regulations have been adopted in your own home countries.
Customs-Trade Partnership Against Terrorism (C-TPAT) is a voluntary partnership programme
between United States Customs and Border Protection (CBP) and business. The aim of the
programme launched in 2001 is to increase supply chain security. Bayer applied for participation in the
programme through its US subsidiary. Its globally operating sub-groups have committed to compliance
with internal corporate security regulations world-wide. Criteria have been defined with regard to
container security, physical security, access control, personal safety, procedural security, IT security,
and training/awareness-building. US Customs validates these measures (no audit) and classifies the
entity according to a three-level system. Entities classified as reliable may expect faster clearance
procedures when importing goods. As a general rule, the higher the security standard demonstrated,
the fewer inspections are carried out. In mid-2007, Bayer was validated in Germany as well. Two CBP
staff inspected and had explained to them the numerous security procedures and measures in place
on site. Bayer is proud of the good outcome of the inspection. Authorised parties may view the results
at the so-called C-TPAT Status Verification Interface (SVI) Overview.
The International Ship and Port Facility Security Code (ISPS-Code) is applicable to maritime
transport. The aim is to raise maritime security and assure the timely discovery and prevention of acts
of terrorism directed against sea transport. The ISPS Code has been in effect since mid-2004. The
competent authority conducts risks analyses to identify weaknesses that are of relevance with regard
to security. The operator develops a customised port security plan on the basis of the analysis. This
plan contains elements such as access control and surveillance of port facilities, checks in areas with