Security culturein the nuclear
field
Published on February 10, 2010doc

referencedoc reference
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the nuclear field
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Security culturein the nuclear
field
First published on September 1st, 2005
IRSN report 2005/54
ISRN/IRSN-2005/54-FR+ENG© IRSN/2010 --- All rights reserveddoc reference
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IRSN
// in brief
The French Institute for Radiological Protection and Nuclear Safety(IRSN) was founded by Act No.2001-398 of May 9, 2001. Its tasks
and organization were defined by Decree No.2002-254 of February
22, 2002. The IRSN is a public establishment that carries out bothindustrial and commercial activities. It is jointly supervised by the
Ministers for Defence, Environment, Industry, Research and Health.
IRSN employs over 1,700 specialists, including engineers,
researchers, doctors, agronomists, veterinarians and technicians,
experts in nuclear safety and radiological protection and in thecontrol of nuclear and sensitive materials.
The Institute performs expert assessments and conducts research in
the following fields:•

nuclear safety;•

safety relative to the transportation of radioactive and fissile
materials;•

protection of human health and the environment from ionizing
radiation;•

protection and control of nuclear materials;•

protection of facilities and transports dealing with radioactive
and fissile materials against malicious acts.

Documents de référence
Editions Property of IRSN
31, avenue de la Division Leclerc
92260 Fontenay-aux-Roses
Tel.:+33(0)1 58 35 88 88
Website: www.irsn.fr
This document may not betranslated, adapted or reproduced
by any means or for any purpose
whatsoever without written
authorisation. For further
information, please contact:
IRSN
Odile Lefèvre
BP 1792262 Fontenay-aux-Roses cedex
Fax:+33(0)1 58 35 79 62

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Foreword
The Institute for Radiological Protection and Nuclear Safety
develops research programs and conducts studies on nuclear andradiological risks. It is responsible for public service initiatives aimed
at prevention and provides technical support to the publicauthorities in charge of ensuring nuclear safety and security,
together with radiological protection. In fulfilling these various
duties, the Institute is called upon to define its position on certain
scientific and technical issues.
In line with its policy of transparency and its desire to make quality
information available to all partners and stakeholders for use indeveloping their own views, the IRSN publishes "reference
documents”, which present the Institute's position on specificsubjects.
These documents are drafted by IRSN specialists, with the help ofoutside experts if necessary. They then undergo a quality assurance
validation process.
These texts reflect the Institute's position at the time of publication
on its Website. It may revise its position in light of scientificprogress, regulatory changes or the need for more in-depth
discussion to satisfy internal requirements or external requests.
This document may be used and quoted freely on condition thatthe source and publication date are mentioned.
We welcome your comments. These may be sent to the address
given in the margin above and should include the reference to therelevant document.

www.irsn.fr

Documents de référence
IRSN
B.P.1792262 Fontenay-aux-Roses cedex
Fax:+33 (0)1 58 35 79 62

doc.syn@irsn.fr

Jacques Repussard
Director General© IRSN/2010 --- All rights reserveddoc reference
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5/24//Members of theworking group
Denis Winter

Submitter

Jacques Aurelle
Bruno Autrusson
Eric Gosset
Jean Jalouneix
Robert Venot

Document produced by the
nuclear defence expertise division of IRSN

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Contents
1/ Introduction

7

2/ Definition

8

3/ Universal features of security culture

9

3/1 Role of the State
3/1/1 Definition of general protection objectives
3/1/2 Division of responsibilities
3/1/3 Protection of information

3/2 Role of Organisations

10
10
10
11

12

3/2/1 Commitment
3/2/2 Management structures
3/2/3 Resources
3/2/4 Vigilance

12
13
13
14

3/3 Role of managers in organisations

14

3/3/1 Definition of responsibilities
3/3/2 Definition and supervision of practices
3/3/3 Qualifications and training
3/3/4 Rewards and sanctions
3/3/5 Audit, review and comparison
3/3/6 Exemplarity

3/4 Attitudes of individuals
3/4/1 Individuals directly involved in security
3/4/2 Individuals not directly involved in security

14
15
15
16
16
17

17
17
18

4/ Safety culture

19

4/1 Similarities

19

4/2 Differences20

4/3 Interactions

21

List of Figures
Figure 1: Main components of Security Culture

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1/

Introduction
The Board of Governors of IAEA has acknowledged 12 fundamental
andprinciples of physical protection for nuclear materials
nuclear facilities . These principles will be integrated into theforthcoming revision of the International Convention on PhysicalProtection. Fundamental principle F proposes a definition of security
culture and recommends that its implementation and its
maintenance are made a priority in the organisations concerned. Itthus appears necessary to specify the concept of security culture.
Note that the other 11 fundamental principles mentioned above
have more or less links with the security culture. They will thus
appear in various terms in the remainder of the text. References will
be made implicitly on various occasions in the text.
whichThis document is also complementary to INSAG-4
presents a concept of safety culture. One specific chapter also
makes the necessary comparisons (common points and specificities)
between safety culture and security culture.

12 Fundamental
principles
A. Responsability of the State
B. Responsabilities during
International Transport
C. Legislative and Regulatory
Framework
D. Competent Authority
E. Responsability of License
HoldersF.

Safety Culture

G. Threat
H. Graded ApproachI.

Defence in Depth

J.

Quality Assurance

K. Contingency Plans
L.

Confidentiality

Document GOV/2001/41
2001/08/15, IAEA

www.iaea.org
Safety Series n°75, INSAG-4

Safety Culture, - a report by theinternational nuclear safetyadvisory group, IAEA, 1991

See the glossary at the end of
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2/

Definitionof security culture
Security culture includes characteristics and attitudes inorganizations and of individuals which establish that the issues
relating to protection against the loss, theft and other unlawful
taking of nuclear material on one hand and deliberate malicious
acts in nuclear facilities or during transport of nuclear materials
on the other hand, receive the attention warranted by theirsignificance.
The malicious acts in question refer to anything that may directly or
indirectly have radiological consequences for man and theenvironment.
This definition is more complete than given in IAEA document ,which relates only to the physical protection of nuclear materials
and nuclear facilities. In addition, INSAG-4 only refers to nuclear
power plants, whereas the current definition extends the field to all
nuclear facilities and the transport of nuclear materials.

Document GOV/2001/41
2001/08/15, IAEA

www.iaea.org

The protection of radioactive substances is not, however, considered
explicitly in this document. An extension could be proposed lateron.

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3/

Universal featuresof security culture
Security culture has three major components. The first concerns thepolicy that the State wishes to put into practice, in particular given
the national and international contexts. The second is theorganisation introduced within each organisation concerned,
particularly to apply the policy fixed by the State: in thiscomponent, distinction must be made between what comes under
the organisation in itself and what concerns its managers. The third
domain is the attitude adopted by the various individuals at alllevels to implement this policy within the framework of thestructure in which it is operating and to incorporate it into theirwork. These aspects are examined separately under the headings ofRole of the State (Paragraph 3/1), Role of Organisations (Paragraph3/2), Role of Managers in Organisations (Paragraph 3/3) and
Attitude of Individuals (Paragraph 3/4). Erreur ! Source du renvoi
introuvable. illustrates the main components of security culture
and links the chapters to the overall diagram.
All these components must, nevertheless, be considered as part of awhole, to develop a security culture through overall coordinationand dialogue between them.
Security culture must not remain confined simply within theorganisations concerned and their personnel; each one in its activity© IRSN/2010 --- All rights reserveddoc reference
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must make an effort to raise public and media awareness tosecurity culture in the nuclear field.
The general public should view security culture as a sign ofprofessionalism, skill and responsibility by all actors (organisations
and individuals) involved in the protection of nuclear materials,
nuclear facilities and transport of nuclear materials. It must help
strengthen the confidence of each one in security within the nuclear
field.
3/1

Role of the StateIn any major activity, the manner in which individuals act isconditioned by requirements set at a higher level. Legislation is thehighest level with an influence on protection against loss, theft or
unlawful taking of nuclear materials and malicious acts in nuclear
facilities and during the transport of nuclear materials; here are laid
the national foundations for security culture.
In the very first instance, the State is responsible for compiling thelegislative and regulatory framework used to define the generalobjectives for protection, division of responsibilities and protectionof information. This framework is discussed fully with all
stakeholders when being developed.
3/1/1

Definition of general protection objectives
The State fixes the security policy. It develops this policy around
identified threats, the international context and specific aspects of
the national context. The State uses these elements in particular todefine the design basis threat.
The design basis threat must be revised periodically to take accountof the constant evolution in risks and technologies. Thus, theprotection implemented to face up to the design basis threat must
be constantly adapted to maintain a permanent, acceptable level.
3/1/2

Division of responsibilities
State commitment is given concrete expression in national
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possibly supported by a technical support body. This authority has
the personnel, financial resources and supervisory powers in termsof security. In particular, provision is made for declaring any event
affecting or likely to affect the protection of nuclear materials,
nuclear facilities and the transport of nuclear materials to thecompetent authority without delay.
So that all organisations and individuals feel involved at theirrespective levels, the State lays out its own responsibilities in termsof the protection of nuclear materials, nuclear facilities and thetransport of nuclear materials clearly as well as those entrusted toother bodies.
The operator has full responsibility for protecting his nuclear
materials, protection equipment, transport means and installations
and for the information he holds. The State, however, withresponsibility for the law enforcement agencies, may be called on tointervene on or off site. It is also justified in intervening when an
event occurs during the transport of nuclear materials, particularlyon the public highway. Lastly, the potential risk from dysfunctionsin the protection of nuclear materials, nuclear facilities or thetransport of nuclear materials may involve the entire national
territory or even spread to other countries.
It is essential for this division of responsibilities to be clearly defined
and well understood by all individuals within the organisations.
Given the need for coordination between the public authorities andother organisms - as required by such a division of responsibilities -,the State introduces mechanisms for the exchange of knowledge
and data, particularly, in terms of intelligence and intervention. It
organises exercises regularly on the protection of nuclear materials,
nuclear facilities and the transport of nuclear materials involving
operators and State departments.
3/1/3

Protection of information
Security culture is different from the culture of secrecy. It must
make it possible for all individuals to be aware of the sensitive
nature of a piece of information. To ensure sufficient protection
against estimated risks, some information may not circulate freely
in the public domain since it could be used for malicious purposes.
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resultant necessary exchanges, the State lays down generalprinciples for authorising access to facilities and information that
could compromise the protection of nuclear materials, nuclear
facilities and the transport of nuclear materials, and checks thatthey are applied.
3/2

Role of Organisations
The policies defined at high level of each organisation concerned are
based on the principles laid down by the State. They condition thework environment and influence the behaviour of individuals. These
policies differ depending on the nature of the organisation and theactivities pursued by its staff, but also show significant common
characteristics, as described in the following paragraphs.
3/2/1

Commitment
Any organisation with activities relating to the protection of nuclear
materials, nuclear facilities and the transport of nuclear materials
makes its responsibilities known and understood publicly in astatement of security policy issued by its Managing Director. The
aim of this statement is to demonstrate the commitment of its
management and to provide guidelines to the staff as well as to set
out the organisation's security objectives.
It varies according to the function of the organisation. For publicauthorities, the commitment focuses more particularly on the
promotion of the security culture. Operators undertake to apply theregulations and seek on-going improvement in the protection of
nuclear materials, nuclear facilities or the transport of nuclear
materials. Lastly, the support bodies (design, manufacture,
maintenance, research, response force, etc.) basically show theircommitment in the quality of their services and compliance withinformation access rules.
In addition, this commitment covers all the various levels of the
defence in depth concept. It must firstly cover prevention systems
before addressing the provisions for detection, early warning,
reaction and limitation of consequences required to protect nuclear
materials, nuclear facilities and the transport of nuclear materials.

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3/2/2

Management structures
Implementing pre-defined policies requires the clear definition in allorganisations of their responsibilities in terms of protection of
nuclear materials, nuclear facilities and the transport of nuclear
materials and methods of controlling its effectiveness. Regardless of
the role of the organisations, strong hierarchical links are forgedthat are used for direct exchanges on matters of security.
Operators appoint dedicated internal units to monitor securityrelated activities. These units report to a high level in the hierarchy.
In addition, within each organisation, responsibility for theprotection of nuclear materials, nuclear facilities and the transportof nuclear materials may be entrusted to individuals not directly
involved in the security field. The internal organisation must,
therefore, foster exchanges and establish structures for dialogue, toanalyse and resolve any difficulties caused by a potential conflict ofinterest between the safety and security provisions.
3/2/3

Resources
The organisation allocates adequate resources to protecting nuclear
materials, nuclear facilities and the transport of nuclear materials
and to making sure it is effective. The personnel thus has thenecessary equipment, facilities and support to fulfil its assignments.
Adequate resources are also made available for staff training.
The resources made available match the expected response withrespect to a particular risk presented by the facility or the transport.
In particular, operators set up sufficient protection to face up to
design basis threats defined by the State.
In addition, operator resources complement those provided by theState departments, particularly the law enforcement agencies, by
taking into account the division of responsibilities mentioned in theprevious chapter.
Lastly, all organisations adapt the resources to be allocated tochanges in short- and long-term threats. They are especially in aposition to react rapidly and put in place the necessary resources to
respond to specific situations.

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3/2/4

Vigilance
All organisations make arrangements for a regular review of theirpractices that form part of the protection system against the loss,
theft or unlawful taking of nuclear materials and against malicious
acts in nuclear facilities or during the transport of nuclear materials.
This covers especially the nominations, the access authorisations,the staff training and, in addition to, the practices linked to thequality of tasks and the protection of information. This regularreview of necessity takes into account lessons learned fromfeedback and changes in the design basis threats. The organisations
make sure in particular that all detected discrepancies relating to
the protection systems are comprehensively analysed andcorrected.
3/3Role of managers in organisations
The work environment has a strong influence on the attitudes ofindividuals. Developing and maintaining a true security culture inindividuals lies in the practices conditioning this environment andencourages the attitudes that contribute to the protection of
nuclear materials, nuclear facilities and the transport of nuclear
materials. The general management is responsible for fixing policies
and protection objectives; managers are then in charge of initiating
practices that comply with them.
3/3/1

Definition of responsibilities
The exercising of individual responsibilities is made easy by clearlydefined chains of command. The responsibilities allocated to eachindividual are established and documented in sufficient detail toavoid all ambiguity; their scope is specified. Thus, are clearly
indicated in particular restrictions on the exchange and circulationof information. The definitions of responsibility are approved by thehighest possible level in the chain of command. Provision is madefor a process to monitor authorisations issued and to put allocatedresponsibilities into practice.

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3/3/2

Definition and supervision of practices
The managers make sure that activities relating to the protection of
nuclear materials, nuclear facilities and the transport of nuclear
materials are strictly carried out.
All the updated documents listed in order of importance fromgeneral directives to detailed work procedures, form the foundation
for good working practices. These reference documents comply withthe organisation's quality policy and include, in particular, a quality
assurance plan for the activity concerned.
The managers ensure that activities are executed as defined and set
up a verification system.
The managers make sure regular contact between theirorganisations be maintained, complying with the rules governing
information confidentiality. Relationships of this type are necessary
when coordinating intervention resources between State
departments and operators. In this context, exercises are organised
to test the organisations and the planned liaisons, train teams andgenerally to draw on the lessons learned to improve theintervention system.
3/3/3

Qualifications and training
Managers ensure that temporary and permanent staff and any selfemployed service provider are made aware of the importance ofprotecting nuclear materials, nuclear facilities, the transport ofnuclear materials and sensitive information. These individuals are
systematically informed of rules to be respected on the subject.
Managers make sure that their staff has all the skills andauthorisations required to perform their tasks linked to theprotection of nuclear materials, nuclear facilities and the transportof nuclear materials.
Recruitment, training and authorisation procedures are established
for this purpose. Exercises and retraining courses are carried out
periodically. The suitability appraisal of individuals relies on both
physical and psychological considerations.

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• 3/Features
Training is not restricted to acquiring technical qualifications or
becoming familiar with the detail of procedures to be followed
strictly. It encompasses a far broader spectrum and, whilst meeting
previously mentioned requirements, it is sufficiently instructive forindividuals to understand the importance of their tasks in terms of
security and the possible consequences of an error.
3/3/4

Rewards and sanctions
Apart from organisational provisions and resources, the behaviour ofindividuals, influenced by both independent and group motivations
and attitudes, dictates whether a practice is satisfactory or not.
Managers encourage and congratulate and attempt to provide
tangible rewards for particularly commendable attitudes towards
the protection of nuclear materials, nuclear facilities and thetransport of nuclear materials.
Managers encourage the personnel especially to report any event
affecting or likely to affect the protection of nuclear materials,
nuclear facilities and the transport of nuclear materials. This
involves inciting the personnel to provide the security staff with any
information that could improve protection that they mightotherwise be inclined to keep to themselves through fear of
sanction or ignorance of the issue at stake.
Nevertheless, managers assume their responsibilities and impose
sanctions in the event of repeated deficiencies or serious negligence,in particular by withdrawing the authorisations given.
3/3/5

Audit, review and comparison
Managers are responsible for implementing a certain number ofmonitoring practices, including regular review of training
programmes, staff nomination and authorisation procedures,
working methods, document control, the quality assurance system
and access to facilities and information.
Managers ensure that events inside or outside the organisation
liable to have an impact on security are analysed and enlarged
upon. Events outside the organisation will be examined and taken
into account if appropriate. It may be relevant to call on specialists
from outside the organisation under this approach.

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3/3/6

Exemplarity
Managers are expected to ensure that their staff comply withestablished security practices and take advantage of them and toincite them continuously through attitude and example to achieve
higher levels of individual performance in performing tasks relating
to the protection of nuclear materials, nuclear facilities and thetransport of nuclear materials.
3/4

Attitudes of individuals
The previous chapters have indicated how the necessary elements
on which to build a true security culture are set in place andemphasises the responsibilities of the State, organisations and their
managers. As indicated in the introduction, it is up to individuals at
all levels to take these elements into account and make the most ofthem. Nevertheless, distinction must be made between the
expected reaction of individuals working in the protection of nuclear
materials, nuclear facilities and the transport of nuclear materials
and those not directly involved.
3/4/1

Individuals directly involved in security
The behaviour of individuals involved in security is characterised by:•a rigorous, prudent approach;•a constant vigilance and a questioning attitude;•

a speed of reaction when faced with an unexpected
situation.

Amongst other things, this category of individuals can be expected
to apply procedures and official rules strictly. They should be awarethat security systems must be compatible with the performance ofother activities in the organisation. In addition, they must operate aprudent, considered approach towards research and divulgation ofconfidential information.
They must also have a steady motivation, with no slackening as
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• 3/Features
receptive and critical of any event or action regarded as suspect. In
such circumstances, the information is sent immediately to thehierarchy, even if it appears to be of minor importance.
Lastly, in the event of a breach of security rules, whether deliberateor through negligence, reaction is immediate using the resources
matching the estimated risk. When faced with immediate danger,
the operator's staff must act rapidly to counteract or delay themalicious act in progress and request assistance from the publicauthorities without delay.
3/4/2

Individuals not directly involved in security
Security culture concerns us all. Any individual involved directly or
indirectly in the protection of nuclear materials, nuclear facilities
and the transport of nuclear materials must be totally immersed init. A duty of vigilance is essential for all.
The expected attitude of these individuals is characterised by:•a knowledge of the principles of protection and taking theminto consideration;•

a compliance with rules and procedures;•

a questioning attitude to abnormal acts or events withregard to the protection of nuclear materials, nuclear
facilities and the transport of nuclear materials. In this case,people in charge of protection are warned systematically.

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• 4/Safety-Security

4/

Safety culture
and security culture
It seems relevant to identify the links between security culture andsafety culture. It is clear that these two cultures interact andcomplement each other in the nuclear field, even if they present
their own specific attributes in certain areas.
This paragraph addresses the similarities and differences in terms ofculture only, ignoring the application of the safety and security
approaches.
4/1

Similarities
Security and safety cultures are normally based on the same
principles in the main. In safety or in security, the same types oforganisations are concerned; for the operators, each organisationmust also ensure that these two cultures live side by side. It seems
logical that the two cultures can only develop and be maintained ifthey are promoted at State level and by managers of theorganisations concerned, as individuals clearly play a role in theirapplication. Lastly, the same type of requirements is found in the
introduction of one or other of these cultures.

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• 4/Safety-Security
4/2

Differences
In terms of human behaviour, safety culture normally revolves
around the risk of human errors whilst security culture takes alsodeliberate acts with the intention of causing harm into
consideration. It is therefore important to integrate notions ofdeterrence and confidentiality in the security culture of allorganisations concerned.
Differences in involvement can be highlighted for organisations andindividuals. For reasons of division of responsibilities andconfidentiality of information, a security culture can only be
developed with extensive State intervention. Taking into accountthe external or internal threat to any one country plus the definitionof scope of responsibility and access to information is the exclusive
remit of each individual State.
In addition, the competent authorities in the fields of safety andsecurity may differ, have different structures and a different type ofsupervisory power.
Worthy of note also is, that large numbers of State departments areconcerned by security culture. In particular, various intervention
bodies are involved in protecting nuclear materials, nuclear facilities
and the transport of nuclear materials. This miscellany of actors, allwith a special role to play, creates an obligation for structures andcommunication, information and exchange systems. Organisations
must understand and complement each other.
Individuals concerned by both these cultures have potentially
specific attitudes, even if appropriation of both cultures isdemanded of them. For safety culture, all individuals are requested
principally to demonstrate a prudent, questioning attitude and toseek to share information with others in an overriding concern fortransparency and dialogue. Security culture requires individuals toshow on occasion a speedy reaction to confirmed or assumed
threats and that they only communicate information to otherauthorised people. However, whereas security clearly involves all
individuals, some are more especially responsible for applying it andsome information must be protected.

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• 4/Safety-Security
4/3

Interactions
The two cultures must not be pitted against each other and one
should not have ascendancy over the other.
It is impossible to envisage merging these two cultures into a single
entity, they must however coexist and reinforce each othermutually.
Each of these cultures must be developed to suit the field of activityof each organisation.
Lastly, these two cultures must be mutually enriching. All possiblesynergy between them must be sought and developed; mechanisms
must be in place to allow permanent exchange.

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• Figure

Figure 1:
Main components of Security
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• Glossary

Glossary
Competent authority: National authority designated or recognised
as such by the State for a precise purpose.
Defence in depth: A concept used to design protection systems
that requires an adversary to overcome several layers and methodsof protection (structural or other technical, personnel andorganizational) or circumvent in order to achieve his objective.
Design basis threat: Attributes and characteristics of potential
insider and/or external adversaries, who might attempt
unauthorized removal of nuclear material or sabotage, against
which a protection system is designed and evaluated.
Nuclear facility: Facility in which nuclear material is produced,
processed, used, handled, stored or disposed of (including associatedbuildings and equipment), if damage to or interference with such
facility could lead to the release of significant amounts of radiation
or radioactive substances.
Nuclear materials: Materials that may be used to manufacture anuclear weapon. Their definition is based on their fissile (for a fission
device), fusible (for a thermonuclear bomb) or fertile (ability to
produce fissile or fusible materials) characteristics.
Nuclear power plant: Nuclear facility including one or several
reactors, with all the structures, systems and components required
to ensure safety and to produce energy, i.e. heat or electricity.
Nuclear safety: All technical provisions and organisational
measures relating to the design, construction, operation, shutdown
and dismantling of nuclear facilities and to the transport ofradioactive substances, intended to prevent accidents and limit theireffects.
Operator: Any organisation or person, applying for authorization or
authorized to exercise one or several activities pertaining to the
nuclear field. This involves in particular the operation of nuclear
facilities and the development, holding, transfer, use and transportof nuclear material.

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• Glossary
Practice: The act of exercising a particular activity, implementing
the rules, the principles of an art or a technique.
Protection: Set of administrative, organisational and technicalprovisions with the following objectives:•protecting nuclear material in facilities and during transport
against theft and other unlawful taking for the purposes ofmalicious use of the said materials;•

protecting nuclear facilities and transport against acts ofsabotage liable to affect the environment and humanhealth;•mitigation or minimizing the radiological consequences ofsabotage.

The provisions for protection designed to satisfy these objectives
include control and accountancy of nuclear materials and physicalprotection systems for facilities and the transport of nuclear
materials.
Quality assurance: Planned and systematic actions necessary toprovide adequate confidence that an item or a facility will function
satisfactorily.
Radioactive substances: Substances emitting ionising radiations
and which, therefore, are governed by provisions for the protectionof man and the environment against the harmful effects of thisradiation.
Sabotage: Any deliberate act directed against a nuclear facility or
nuclear material in use, storage or transport which could directly or
indirectly endanger the health and safety of personnel, the public
and the environment by exposure to radiation or release ofradioactive substances.
Safety culture: is that assembly of characteristics and attitudes inorganisations and individuals which establishes that, as anoverriding priority, nuclear plant safety issues receive the attention
warranted by their significance.
Transport: International or domestic carriage of nuclear material by
any means of transportation beginning with the departure from afacility of the shipper and ending with the arrival at a facility of thereceiver.

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