Progress: Addressed, Not Adequately
DOT Relevance: 172 Subpart I
This key area pertains to security plans that are required for the transportation of hazardous materials such as would be required by the fuel supply infrastructure supporting hydrogen fueled vehicles under most scenarios. These requirements are specified in 172.800 (Purpose and Applicability), 172.802 (Components of a Security Plan), and 172.804 (Relationship to Other Federal Requirements). Review of the applicability provisions in 172.800 indicates that these DOT security plan regulations would apply to many of the fuel-supply infrastructure scenarios being considered as candidates for commercialized hydrogen fueled vehicle operations.
This key area is judged to be of medium criticality because the regulations contained in 172.800, 172.802, and 172.804 appear to be appropriate and directly applicable to potential hydrogen vehicle fuel-supply infrastructure requirements, and because it is anticipated that organizations that might transport hazardous materials as part of such an infrastructure will be experienced in this area and capable of addressing the security plan requirements.
Progress toward developing security plans for hazardous material transportation as part of hydrogen vehicle fuel supply infrastructure is rated at Addressed, Not Adequately. This is because, as mentioned above, it is anticipated that organizations responsible for hydrogen vehicle fueling infrastructure hazardous material transportation will be able to meet the security plan requirements. Moreover, it is anticipated that some existing hazardous materials transportation security plans are partially applicable, although this has not been verified.
ASME Innovative Technologies Institute, LLC is working on a new standard for Risk Analysis Methodology for Critical Asset Protection (RAMCAP). This new standard may be applicable to many of the security issues discussed. The standard is expected to be available by the end of 2006.
It is recommended that the development of hydrogen vehicle commercialization should be monitored with emphasis on the fuel supply infrastructure in general and any unique security planning requirements in particular. Any need to refine 49 CFR 172.800, 172.802, or 172.804 should be assessed, and potential programs to support security planning work should be considered. At a higher level, if and when it appears that hydrogen vehicles will be commercialized, DOT, the Department of Homeland Security, and perhaps responsible state agencies should cooperate to determine if there are any new or special security issues that should be addressed.