I had an anonymous reader take me to task yesterday about my post on the recent TSA ICR for their ground transport security program. That comment posted to this blog and a lengthier version posted (apparently by the same person) to the Hazmat Transportation discussion group on LinkedIn took objection to “the comment that ‘TSA’ is the expert in transportation security”. I can’t find such a statement in by blog posting, but just in case I let something creep into the tone that implied that I feel that it is necessary to address that issue.
TSA Doesn’t Do Ground
After the jets crashed into three buildings in 2001 in a coordinated terrorist attack on the United States, the TSA was stood up to address ‘transportation security’. In actuality Congress targeted them on air passenger security as that was the most obviously broken part of transportation security. This wasn’t necessarily the most broken, just the most obviously broken; thousands of people dying on national TV because of multiple security breaches is pretty obvious.
Besides being politically the most important transportation security problem to fix, passenger screening was also the easiest to fix. There are fixed points that people have to go through to get to their seats on the airplanes. Checking people coming through those checkpoints is a relatively easy task; please pay attention, I said ‘relatively easy’. Protecting trainloads or truck loads of hazardous chemicals moving about the country is much harder.
Congress continues to short change the ground transportation role of TSA. The political reason is simple, an effective security monitoring program for truck and rail hazmat transportation is going to be very expensive and complicated. Since no one has bothered to attack either of these transportation modes yet, Congress feels free to ignore them; that has always been the way Congress deals with expensive complicated issues.
DOT Has Done Transportation Security
DOT did not completely ignore transportation security before the towers fell. In many ways safety and security are interlocked. Many safety measures serve a security purpose as do many security measures serve safety. Security just was never a major focus of DOT; once again that can be traced by to Congress. If Congress doesn’t fund it, it aint gona happen anytime soon.
When TSA was stood up in DOT, all of the security functions were supposed to have been turned over to TSA, except, there are always exceptions. The most obvious exception was the Coast Guard and maritime security; the TSA administrator would help but the Commandant would do the heavy lifting. Hazmat security plans for trucking was another area that missed the move.
With the move of TSA to DHS the security funding within the DOT essentially dried up. There were people left with security backgrounds, but they reported to safety people not security people. In reality, they never did report to security people, that was what was wrong with security before September 2001; security folks always reported to someone else, someone not interested in security.
TSA Security Model
TSA has a very firm security model for air passenger security; they do the security, they manage the security, and they regulate the security. That is a very expensive security model. If that model were applied to the hazmat trucking industry there would be a TSA inspector at every terminal, loading and unloading location that handled hazmat. For rail hazmat security there would be an inspector at each loading, transfer, and unloading site to ensure the security of those operations. The application of the current TSA security model to those two modes would quickly dwarf the size and expense of their current operations at airports around the country.
To its credit, TSA appears to be trying a potentially much more effective security model for hazmat security by truck and rail. Using inspector site visits to hazmat trucking companies and railroads, TSA has been collecting information about current security practices through voluntary corporate security reviews and will continue that process using their new BASE program discussed in my earlier blog post.
What will Congress Authorize
If and when Congress provides the authorization to establish an effective hazmat ground transportation security plan, TSA should have a good idea of where the industry as a whole is at in establishing security planning. When it does so, it should be able to set up a cooperative risk-based security program that industry executes and TSA oversees.
Whether that will actually happen or not depends on why Congress decides to regulate hazmat transportation security. If they wait until a successful terrorist attack results in thousands of casualties due to the release of a toxic inhalation hazard chemical intentionally released from a railcar or tank wagon, the imposed system will be poorly conceived, poorly executed and very expensive.