High-Consequence DG Security
Most Dangerous Goods present risks because of their physical or chemical properties. But some dangerous goods present an additional risk: they could be deliberately misused to cause serious harm.
These are known as High Consequence Dangerous Goods (HCDG).
Under ADR and RID, HCDG are Dangerous Goods that have the potential for misuse in a terrorist incident and which could, as a result, produce serious consequences such as mass casualties or mass destruction. For Class 7 radioactive material, the definition also includes the potential for mass socio-economic disruption.
This means that businesses involved in the transport of certain Dangerous Goods need to think beyond conventional safety and compliance. They also need to consider security — including the possibility of theft, unauthorised access, deliberate misuse and the threat posed by people who may have legitimate access to dangerous goods.
For organisations that consign, transport, store or otherwise handle HCDG, this can create a number of potential problems:
Knowing whether your dangerous goods are actually HCDG — not every Dangerous Goods consignment is subject to the additional HCDG requirements. The rules depend on the class, substance and, for many substances, the quantity being transported. Determining whether Chapter 1.10 applies can therefore require careful consideration of the dangerous goods being handled.
Understanding that security is different from safety — conventional Dangerous Goods procedures are primarily designed to prevent accidents and protect people and the environment. HCDG security provisions are intended to reduce the possibility of Dangerous Goods being stolen or deliberately misused. Businesses therefore need to consider a different set of threats and vulnerabilities.
Carrying out an effective security risk assessment — organisations need to consider the security risks associated with their operations, including vehicles and journeys, sites, temporary storage, personnel and information. The assessment needs to reflect how the business actually operates rather than simply being a generic document.
Developing and implementing a transport security plan — where the HCDG provisions apply, consignors, carriers and other relevant participants must adopt, implement and comply with a security plan. The plan needs to address responsibilities, the Dangerous Goods involved, security risks, risk-reduction measures, incident procedures, testing and review, and protection of security-sensitive information.
Making sure the security plan works in practice — having a document called a “security plan” is not enough. The arrangements need to be implemented, tested, reviewed and kept up to date. DfT guidance recommends regular testing and review, including exercises involving scenarios such as theft, hijacking and cybersecurity incidents.
Managing the insider threat — security risks are not limited to someone breaking into a depot or stealing a vehicle. Employees, contractors, agency workers and other people with legitimate access can create vulnerabilities. Appropriate recruitment, identity and employment checks, access controls and security awareness therefore form an important part of the overall approach.
Choosing and managing transport providers carefully — Dangerous Goods should only be offered to appropriately identified carriers. Where HCDG are involved, businesses need confidence that their transport partners have suitable security arrangements, trained personnel and, where required, their own security plan.
Securing vehicles, goods and temporary storage — security arrangements need to consider the whole journey, including stops, depots, terminals and temporary storage. Vehicles and their cargo also need appropriate anti-theft measures that remain operational and effective.
Training people to recognise security threats — everyone involved in Dangerous Goods transport needs appropriate security awareness training. This includes understanding the nature of security risks, recognising suspicious activity, knowing how to reduce risks and understanding what to do following a security breach.
Keeping security-sensitive information secure — transport schedules, Dangerous Goods information, security plans, routes and other operational information can themselves create vulnerabilities if they fall into the wrong hands. HCDG security plans therefore need measures to control access to sensitive information and limit its distribution to those who need it.
Preparing for changes in the threat environment — security arrangements that are appropriate today may not be appropriate tomorrow. Changes in threat levels, operating locations, personnel, transport routes, contractors, technology or the types of Dangerous Goods being carried can all affect the security risk.
Knowing who is responsible for what — security is a shared responsibility involving consignors, carriers, drivers, site personnel, contractors and management. Without clearly defined responsibilities, important security controls can easily fall between the gaps.
Being prepared for regulatory scrutiny — the Department for Transport monitors compliance with the mandatory security requirements of ADR and RID Chapter 1.10 and has powers to carry out both announced and unannounced inspections.
The challenge is that HCDG compliance isn't simply about having the right paperwork or putting a Dangerous Goods placard on a vehicle.
It requires an organisation to understand its security risks, identify vulnerabilities, protect Dangerous Goods throughout the transport chain, train its people and have effective procedures for preventing and responding to security threats.
And importantly, the consequences of getting security wrong can extend far beyond regulatory non-compliance. Theft, diversion or deliberate misuse of high consequence Dangerous Goods could have serious consequences for people, businesses, infrastructure and the wider public.
The good news is that you don't have to navigate these requirements alone.
Roadsafe can help you understand whether HCDG requirements apply to your operations, assess your security risks, develop and review transport security arrangements, and provide the training your people need to recognise and manage security threats.
Explore our training and consultancy solutions below to find out how we can help you manage High Consequence Dangerous Goods safely, securely and compliantly.