DOT Site Security Plans: Potential Application to Pipeline as Offerors

September 2016, Vol. 243, No. 9

By Jason Hutt and Elizabeth Corey, Bracewell LLP

The Department of Transportation (DOT) requires “offerors” of hazardous materials to develop and adhere to a site-specific security plan that evaluates transportation security risks and appropriate measures to address those risks. For the midstream sector, questions often arise as to whether or not the activities of a pipeline owner or operator trigger DOT’s site security plan requirements. We briefly address the relevant regulations as well as some of the actions that may trigger these planning requirements.   History Under the Hazardous Material Regulations (“HMRs”), 49 C.F.R. Parts 171-180, the DOT’s Pipeline and Hazardous Materials Safety…

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