Saturday, July 17, 2010

OMB Approves Reinstatement of Highway CSR

On Thursday the Office of Management and Budget (OMB) approved the reinstatement of the TSA Highway Corporate Security Review program. Instead of the requested three-year approval the OMB only provided a one year re-instatement of the information collection request (ICR – 1652-0036). OMB required TSA to provide a report on the efforts to improve the CSR program within six months. The OMB noted that:
“Consistent with the Surface Transportation Security Priority Assessment Implementation Plan, TSA should work with the DoT [sic] to implement an integrated Federal approach for security assessments, audits, and inspections to produce more thorough evaluations and effective follow-up actions for reducing risk, enhancing security, and minimizing burdens on assessed surface transportation entities. TSA should also coordinate data requests with the established single data repository to avoid redundant efforts, take advantage of existing data sets, and establish data access control. Within six months TSA should provide to OMB a status report regarding these efforts.”
As I noted in an earlier blog this CSR program deals with the collection of information from owners and operators of school bus, motor coach, and trucking (general freight and hazardous materials) companies during corporate security review visits by TSA Surface Inspectors. The information collected during these face-to-face visits is used to “establish the current state of security practices for highway modes of transportation. TSA will then be able to make policy and programmatic decisions to improve the overall security posture within the surface transportation community.” (74 FR 57326) Last summer I noted that as many as three TSA inspectors conduct these interviews. Typical interviews last two to three hours and cover “eleven topics: Management and oversight of the security plan, threat assessment, criticality assessment, vulnerability assessment, personnel security, training, physical security countermeasures, en route security, information technology security, security exercises and drills, and a hazardous materials addendum” (74 FR 28264). TSA expects to conduct 400 of these CSR within the next year. Since they are targeted at all commercial surface wheeled transportation, there is no telling how many of these will actually be targeted at trucking companies carrying hazardous materials. With the old program only conducting 100 CSR per year, whatever the number of hazmat trucking inspections actually is, it will likely be a significant increase over the previous program.

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