Fred Millar, a rail security consultant for Friends of the Earth, posted a comment on yesterday’s blog (see: "Railroad Hazmat Route Selection Rule"). He voiced his objections to the rule’s failure to require carriers to route hazmat shipments around major cities. He makes the point that this "rerouting policy leaves our cities vulnerable to attacks on trains carrying hazardous rail cargoes’.
He comments that this rule allows carriers to "unilaterally select dangerous routes through or around major cities for chemical railcars" while technically an exaggeration (the FRA and TSA are supposed to review the routing decisions), he is effectively correct. Neither the FRA nor the TSA inspectors will have enough time to effectively review multiple routing analysis documents during site visits; especially considering that there are 27 factors that should be included in each analysis.
To make this rule effective, the FRA and TSA would have to employ hundreds of new inspectors for their review to have any significant effect on carrier decision making. Or use ‘third party’ inspectors like those envisioned in the Chemical Facility Anti-terrorism Act of 2008 (currently making its very slow way through Congress).
Fred has established a new Journal on AOL, ReRoute-Now, with a more detailed review of this issue as the inaugural entry. Since this is only peripherally a chemical facility security issue, I’ll make a more detailed reply to his comment on that site.