Hazardous Materials and Cargo Security Plan

The elements of this plan are applicable to all entities, current and future of our company.

Our company and its agents handle a variety of freight through several different means, truckload, LTL and intermodal to name a few. Thus each specific mode may require slightly different procedures. However, this plan is designed to encompass most methods of transportation and yet, be specific enough to deal with more direct threat problems. Though the company does relatively little in the way of hazardous materials transport, we are dedicated to being prepared and cable of dealing with any situation that may arise.

In the event of an emergency, refer to the appropriate section of our Emergency Response manual and follow the procedures outlined there.

1. All Hazardous materials loads handled by TransPro Intermodal Trucking Inc., must be accounted for at all times. Hazardous materials loads are required to have proper documentation.
2. The Hazardous Materials Regulations found in 49 CFR$ Part 172 will be the primary classification source for chemicals addressed in this policy.
3. Considering the changing nature of our business, the security risk assessment as outlined below may not remain accurate over time. Therefore, at a minimum the Risk Manger will conduct an annual security risk assessment and implement appropriated changes if any within 60 days of the assessment.

WARNING: This record contains Sensitive Security Information that is controlled under 49 CFR parts 15 and 1520. No part of this record may be disclosed to persons without a "need to know", as defined in 49 CFR parts 15 and 1520, except with the written permission of the Administrator of the Transportation Security Administration or the Secretary of Transportation. Unauthorized release may result in civil penalties or other action. For U.S. government agencies, public disclosure is governed by 5 U.S.C.552 and 49 CFR parts 15 and 1520.

Given that:

1. The nature of TransPro Intermodal Trucking Inc., business is the distribution of freight of all kinds, including different hazard classes and
2. The quantities of these shipments can vary from a 5 pound box to a 4000 pound bulk container, loaded in containers or vans weighting as much as 50,000 pounds which,
3. Travel through major metropolitan areas, from
4. Hundreds of different origins to hundreds of different destinations, it is resolved that the probability risk of a security incident is as follows:

Note: Management’s knowledge of the distribution system, the nature of the hazardous materials involved was used in the following determinations of risk assessment. Periodically management will review the assessment conducted by the Risk Manager to review the probabilities listed. On a scale of 0-100%, 0% means no risk probability, 100% means severe threat probability. These probabilities represent an intuitive assessment of risk from management.

Since the frequency of explosive loads is limited to Division 1.4 (approximately 6-10 loads per year) and the size of such shipments is non-bulk packages loaded in a container or van at one time, it is our estimate that the degree of vulnerability is 50% due to the placarding requirements. However, since the potential impact of the use of fireworks as weapons of mass destruction is low our overall assessment of risk for explosives is scored at 15%.

Compressed Gases

Non-bulk cylinders of compressed gases are shipped occasionally through our distribution system; therefore the degree of vulnerability is medium at 50%. Since these cylinders may be used as a component of a weapon our assessment of risk for compressed gas in 30%.

Flammable Liquids

The shipments made within our distribution system are primarily paints, flammable PGII and PGIII ranging in size from one gallon cans to 4000 pound portable tanks. Therefore the degree of vulnerability for flammable liquids is deemed to be high at a rate of 50%. Since flammable liquids may be a component of a weapon as well as pose a significant threat itself, our determination for the potential impact of the risk for flammable liquids is 60%.

Oxidizers

The few shipments made within our distribution system that involve oxidizers are in non-bulk packages in very limited quantities. Oxidizers are generally used as a catalyst to get a reaction started and therefore could be useful in a weapon of mass destruction. The degree of vulnerability for oxidizers is very high at 75%. Our determination for the potential impact of the risk for oxidizers is 75%.

WARNING: This record contains Sensitive Security Information that is controlled under 49 CFR parts 15 and 1520. No part of this record may be disclosed to persons without a "need to know", as defined in 49 CFR parts 15 and 1520, except with the written permission of the Administrator of the Transportation Security Administration or the Secretary of Transportation. Unauthorized release may result in civil penalties or other action. For U.S. government agencies, public disclosure is governed by 5 U.S.C.552 and 49 CFR parts 15 and 1520.

Poisons

The few shipments containing poisons, especially poisons by inhalation hazard, may be considered a weapon of mass destruction in their existing form. Therefore the potential impact of risk for poisons in our system is medium to high 65% regardless of quantity.

Corrosives

The shipments of corrosives are typically shipped in the form of different sizes of batteries in non-bulk packages. The maximum weight is 40,000 pounds per shipment. Due to the potential of high jacking for the chemicals to be used in weapons of mass destruction, the degree of vulnerability for corrosives is high at 80%. Violent reaction can be expected; as a result of the use of corrosives in a mixture therefore causing the potential impact of risk for corrosive in our system is high at 50%.

Miscellaneous

Several shipments of Class 9 move through our system on a fairly regular basis resulting in a vulnerability of an incident of 50%. However, the risk of a Class 9 being used in a weapon of mass destruction are estimated to be very low, therefore our overall estimate of potential risk for miscellaneous materials is 15%.

1. Verify that drivers and contractors are US citizens or that non-citizens have documentation appropriate to their immigration status. We will only accept the forms as listed on the INS-9 form as valid proof.
2. Ensure that drivers have current CDL licenses with the appropriate endorsements and another form of identification (i.e. company issued credentials; current medical certificate, etc.).
3. Collect company identification cards and any security materials when a driver or employee or contractor leaves the company. Update and cancel passwords to prohibit computer access by former employees.

WARNING: This record contains Sensitive Security Information that is controlled under 49 CFR parts 15 and 1520. No part of this record may be disclosed to persons without a "need to know", as defined in 49 CFR parts 15 and 1520, except with the written permission of the Administrator of the Transportation Security Administration or the Secretary of Transportation. Unauthorized release may result in civil penalties or other action. For U.S. government agencies, public disclosure is governed by 5 U.S.C.552 and 49 CFR parts 15 and 1520.

1. Management will designate who is in charge of security for the company and at each facility. Terminal managers will be in charge of security unless otherwise notified by the President of the company that another person has been assigned this task.
2. Management will conduct security awareness training for all employees, agents and contractors, including how to report suspicious incidents or events.
3. Supervisors will require all visitors and outside vendors to a terminal to sign in and be either given a visitors pass or be escorted by a company employee at all times. Designated parking areas for visitor vehicles shall be established as appropriate.
4. Designated personnel will perform daily yard checks and equipment reconciliation. Discrepancies in vehicle counts and locations shall be resolved immediately. If equipment is missing contact the appropriate police agency immediately.
5. Designated personnel will remove keys from tractors not is use and place them in a secure key storage location.
6. All employees, agents and contractors should control access to computers, especially those with product and routing information.
7. The company may request periodic checks of facility areas by local law enforcement, especially when a terminal in not open and consider a profession security force at higher risk terminals during Orange or Red condition alerts.
8. The company may develop specific actions for each security level alert that might be set by the Department of Homeland Security.
9. The company may consider use of seals for certain products or routes.
10. The company will make advisory notices of any change in the nation’s threat level as directed by the Department of Homeland Security.
11. The company will post and periodically review anti=terrorism tips.
12. Management will inspect facility grounds, maintenance areas, and building to identify points of possible unauthorized entry to the property.

    WARNING: This record contains Sensitive Security Information that is controlled under 49 CFR parts 15 and 1520. No part of this record may be disclosed to persons without a "need to know", as defined in 49 CFR parts 15 and 1520, except with the written permission of the Administrator of the Transportation Security Administration or the Secretary of Transportation. Unauthorized release may result in civil penalties or other action. For U.S. government agencies, public disclosure is governed by 5 U.S.C.552 and 49 CFR parts 15 and 1520.

13. Periodically, the company may test emergency response communications equipment and procedures.

Loads must not be transported without verification of seals. The seal (if required) must be applied at the Shipper’s location and be noted on the bill of lading. It is the responsibility of the driver to confirm this has been done. Further, the driver must confirm the seal recorded on the bill of lading matches the seal on the unit. Any discrepancies must be immediately report to dispatch. Dispatch will advise the driver on actions he/she should take and then will contact the third party or other personnel as required.

When the driver picks up the shipment at a dock/ramp or pier he/she must inspect the seal to ensure it is intact. The doors should also be inspect4ed for signs of tampering. If the driver sees anything suspicious he/she should report this to dispatch and to the appropriate personnel on site. If problems are found, they must be resolved prior to leaving the shipper location.

1. If possible observe the loading of your unit.
2. Verify there are no suspicious onlookers during the cargo loading.
3. Determine if the route and immediate staging areas appear clear.
4. Conduct safety inspection; inspect tires, brakes and other mechanical items for damage.
5. Determine if all Tractor-Trailer access panels and doors are locked and seals remain intact/uncompromised.
6. Communications devices should be checked to insure they are functioning in the event you need them in an emergency.

WARNING: This record contains Sensitive Security Information that is controlled under 49 CFR parts 15 and 1520. No part of this record may be disclosed to persons without a "need to know", as defined in 49 CFR parts 15 and 1520, except with the written permission of the Administrator of the Transportation Security Administration or the Secretary of Transportation. Unauthorized release may result in civil penalties or other action. For U.S. government agencies, public disclosure is governed by 5 U.S.C.552 and 49 CFR parts 15 and 1520.

1. When leaving a location be aware of any possible surveillance of your location or your truck. Criminal surveillance often begins at, or within a mile of your origin. Report suspicious activity to dispatch and the police.
2. When possible, go directly to your delivery point without making stops.
3. Remain particularly observant for suspicious activities in and around your en-route stops. Report any suspicious activity to police and dispatch.
4. Keep all tractor-trailer doors and access panels locked and your windows rolled up.
5. Maintain regular communications with your dispatcher.
6. Vary your route when possible.
7. Don’t discuss your cargo, destination, or trip specifics with people you don’t know or on open channels or in places where your conversations can be overheard.
8. Do not discuss routes with any shipper personnel unless instructed by your company to do so.
9. Do not pick up hitchhikers.
10. Carry information regarding the equipment you are operating. You will need license plate numbers, container or trailer numbers and a description if equipment is stolen. Police cannot make a report without this information, have it handy prior to departure.

1. Sales and supervisory personnel should not accept business from an unknown party before verifying the company’s legitimacy.
2. Drivers and terminal personnel shall ensure that doors are locked at all times when not manned or attended. Ensure that all windows are closed.
3. If possible, drivers and terminal personnel should lock steering columns when a tractor is not in service.

   WARNING: This record contains Sensitive Security Information that is controlled under 49 CFR parts 15 and 1520. No part of this record may be disclosed to persons without a "need to know", as defined in 49 CFR parts 15 and 1520, except with the written permission of the Administrator of the Transportation Security Administration or the Secretary of Transportation. Unauthorized release may result in civil penalties or other action. For U.S. government agencies, public disclosure is governed by 5 U.S.C.552 and 49 CFR parts 15 and 1520.

4. Drivers should perform a “walk-around” inspection of the vehicle after every stop, including deliveries and breaks. Be sure to look under the trailer and in hose tubes where a device could be attached. Check to be certain your trailer is still sealed with the proper seal.
5. To the extent possible, reduce pre-loading. Terminal personnel should designate an area for pre-loaded trailers. Put glad-hand locks or kingpin locks on spotted loaded trailers. Regularly check this area.
6. Supervisors should develop “parking instructions” for any location away from a terminal. Look for lighted and fenced areas, with good visibility and security.
7. Drivers should never leave vehicle unattended in insecure, dimly lit areas.
8. Supervisors shall include security considerations in the selection of routes and times for pick-up and delivery. When possible, avoid bridges, tunnels and densely populated areas.
9. Dispatchers and supervisors will minimize driver down time while in route. In cases of breakdowns, priority will be given to get the vehicle moving again. Schedule and dispatch with as few required stops as possible.