Friday, March 6, 2009

TSA on DHS Leadership Journal

Gale Rossides, the Acting Administrator for TSA, had a blog posting on the DHS Leadership Journal earlier this week. The posting provided a quick look at the progress TSA is making on security of TIH rail shipments. There is nothing here that readers of this blog have not already heard. What is more interesting is what is missing. Claims of Risk Reduction The blog notes that TIH chemicals represent less than 1% of the total railroad shipments each year but they represent “a potentially serious risk in America's densely populated urban areas”. The blog claims that TSA started early work with the railroads by avoiding a “a lengthy rulemaking process” and instead worked in partnership with the railroads to reduce TIH risk by implementing “several key security measures including tracking and substantially reducing the standstill time for unattended freight cars transporting TIH materials in high threat urban areas, developing site-specific security plans, and providing security training for front line employees”. The blog claims that the result has been that “rail TIH risk has been reduced by more than 70 percent.” While I certainly agree that reducing standing time on rail tracks reduces the risk of a successful terrorist attack I vehemently object to the 70% risk reduction figure. Since no one has claimed that there has been a reduction in the number of TIH shipments through high threat urban areas (HTUA) it is disingenuous to claim such a large risk reduction. The consequence side of the risk equation is so large that the only way to achieve such a large risk reduction is to reduce the number of shipments through these areas. Even the railroads recognize that the shipment of TIH chemicals through HTUA presents a potentially catastrophic hazard. According to the Journal of Commerce the UP has recently petitioned the Surface Transportation Board for “guidance about our obligation to quote rates for new, lengthy movements of chlorine in situations where the transportation would require movement through several High Threat Urban Areas”. Rerouting Issue Ignored Neither the Acting Administrator’s blog nor the UP’s petition addresses the issue of routing these shipments around these urban areas. In TSA’s case it can be argued that the re-routing issue is being handled by the Federal Railroad Administration. For the UP to ignore their ability to re-route around many of these urban areas brings into question their motivation. Rail Security Rule The TSA blog does note that the freight rail security rule recently finalized by TSA will take additional measures to reduce the risks associated with TIH chemical shipments. The big difference between this rule and the earlier collaborative efforts is that these rules provide TSA with the clear authority to inspect and enforce the rules. While voluntary efforts are to be commended, it is only through effective enforcement actions that the government can ensure that all of the players are taking effective actions to increase security of these shipments.

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