Thursday, May 28, 2009

Reader Comments – 05-27-09 – Approved Training List

Yesterday our good friend Anonymous left a comment on the HR 2200 update blog. The comment was inspired by the requirement §306(b) for DHS to “identify criteria and establish a process for approving and maintaining a list of approved private thirdparty providers of security training with whom surface transportation entities may enter into contracts, as needed, for the purpose of satisfying security training requirements of the Department of Homeland Security”. Anonymous writes:
“I wonder what kind of a step forward DHS is taking in "be required to identify criteria and establish a process for approving and maintaining a list of approved private third-party providers of security training"...What I hope they do is take a long hard look at the maritime security training approval process, and avoid making the MTSA mistakes.”
I’m not sure what ‘MTSA mistakes’ Anon is talking about, but I have only been casually looking at MTSA regulations for a short time. I certainly haven’t been covering MTSA news in anything more than a cursory manner. If anyone can point me in the direction of these ‘MTSA mistakes’, I would certainly appreciate it so I can look into this for lessons learned before we get to that point for TSA. I am a firm believer that a smart person learns from their own mistakes, a truly wise person learns from the mistakes of others. To be clear though, DHS isn’t looking at this yet; Congress is. If the bill passes and these provisions remain intact, then TSA will eventually have to figure out how to make them work. This will involve the writing of regulations so there will be time for us to publicly comment on previous mistakes in that process. I hope that Anon will remember these concerns when it comes time to write comments on the ANPRM or NPRM.

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