Motor Carrier TSA Security Compliance Checklist

49 CFR 172.704(a)(4) requires in-depth security training for every hazmat employee within 90 days of hire and at least every three years thereafter. Cover company-specific security objectives, the security plan, and each employee's role in preventing en-route theft or diversion. Attach the signed training acknowledgment to the DQ file.

Refresher covers current threat indicators, suspicious-activity reporting (1-855-368-4357), and any plan changes since last cycle. Drivers who missed live training get the recorded session within 14 days.

Walk the perimeter for cuts, gaps, and washouts. Confirm gates close and latch under their own weight, and that the after-hours gate camera covers the full approach.

Pull random clips from the past week to confirm DVR retention is at least 30 days, timestamps are accurate, and night-vision is functional at the fuel island and trailer drop yard.

Quarterly rotation of shared codes; immediate revocation for any driver or shop tech who left employment in the prior 90 days. Reconcile the active fob list against payroll.

For drivers running drayage at MTSA-regulated terminals, confirm each TWIC is unexpired and matches the driver currently assigned to the lane. Pull replacements 60 days ahead of expiration to avoid lockouts at the gate.

Required for carriers hauling Table 1 hazmat (e.g., Division 1.1/1.2/1.3 explosives, bulk Class 3 PG I/II, RAM, select agents). Re-review personnel security, unauthorized-access, and en-route security sections; document any operational changes since last review.

If commodities or lanes changed in the last 12 months, refresh the assessment. New routes through urban core or near soft targets typically need additional en-route controls (check calls, geofence alerts, no-overnight-park lists).

49 CFR 172.602 requires a 24/7-monitored emergency response number on every hazmat shipping paper. Verify CHEMTREC (or equivalent) account is paid through the next renewal and the contract number printed on BOLs matches the active account.

Spot-check ten recent BOLs. Each must list proper shipping name, hazard class, UN ID, packing group, total quantity, and the 24/7 emergency response phone. Missing emergency contact info is a roadside OOS for hazmat loads.

High-security seals (ISO 17712) on hazmat trailers; record seal number on the BOL and on the dispatch record. Driver photographs the intact seal at pickup and at delivery.

For placardable loads, route around tunnels and posted hazmat-restricted corridors. Compare dispatched route to the carrier's route-compliance map; flag any deviation for dispatcher approval before departure.

When a load was rerouted off the standard hazmat-compliant lane, capture who approved, why, and the alternate route. File with the trip packet so the audit trail survives a TSA Corporate Security Review.

Confirm Motive/Samsara geofences are set on hazmat origin, fuel stops, and consignee. Off-route or extended-stop alerts go to the on-call dispatcher; document responses to any alert that fires during the cycle.

Pre-employment full Clearinghouse query plus MVR from every state held in the past three years. Re-pull annually under Part 391.25 and run the limited Clearinghouse query.

HME (H or X) requires a TSA Security Threat Assessment renewed every five years. Build a 90-day reminder so drivers don't lose dispatch eligibility mid-renewal.

Inquiries to all DOT-regulated employers from the past three years must be on file within 30 days of hire. A driver hauling hazmat without complete inquiries is a paperwork violation that compounds with any safety event.

If the DQ packet is missing required items (MVR, Clearinghouse, prior-employer inquiries, HME STA), pull the driver from any placardable runs until the gap closes. Notify dispatch in writing so the hold survives a shift change.

Reportable events include actual or attempted theft of hazmat, suspicious surveillance of facility or driver, en-route diversion, or loss of a placarded load. Log even minor anomalies — patterns matter to TSA Surface Inspectors.

Call the Transportation Security Operations Center (1-866-615-5150) within 24 hours of a hazmat security incident. Report to local law enforcement at the scene and file the FMCSA accident register entry within 30 days if a reportable accident occurred alongside.

Place a litigation hold on the affected tractor's dashcam (full event window plus 30 minutes either side), ELD edits, gate access logs, and yard surveillance. Pull and store off the device — DVR auto-overwrite on a 30-day cycle has destroyed defenses before.

Safety director, dispatcher, and the involved driver review what happened, what controls failed, and what plan revisions follow. Document changes in the security plan revision log so the next 172.800 review can show closure.

Walk dispatch and driver-manager staff through a scripted scenario — hijacked load, suspicious surveillance at the yard, missing trailer at a drop lot. Capture decision points and timestamps; the exercise itself counts toward the 172.704 security training cycle.