Saturday, December 4, 2010

DOT TIH Route Analysis Grant

There is a brief note over on ProgressiveRailroading.Com about DOT, presumably the Federal Railroad Administration, awarding a Railroad Safety Technology Grant to the Railroad Research Foundation (RRF). According to the article the $1.5 million grant will be used to “to enhance and implement the Rail Corridor Risk Management System, a web-based software tool designed to analyze the safest, most secure routes to transport certain hazardous materials”.

According to the RRF web site this grant is apparently providing continued funding to a multi-year (2005-2008) program that had previously received grant funding from the DHS Freight Rail Security Grant Program. That earlier program had also provided funding for the development of a Rail Corridor Hazmat Response and Recovery Tool as well as the development of “‘Safe Haven’ Concepts for In-Route Toxic Inhalation Hazard (TIH) Shipments”.

Long time readers of this blog will remember that I have long advocated the development of a web-based software application to conduct the route analysis currently required for the shipment of toxic inhalation hazard (TIH) chemicals. The PHMSA route analysis rule provides a requirement for railroads transporting TIH chemicals to analyze their current routes and potential alternative routes for those shipments based upon 23 different safety and security factors. A coherent, reproducible analysis is patently not possible without a sophisticated software tool.

Any such tool developed will be controversial. The PHMSA rule requiring the analysis via the 23 different factors did not provide any guidance on how to weight the different factors in the analysis process. Since one of the factors (and certainly a legitimate factor in my mind) was cost many people who question the inherent safety of TIH shipments fear that railroad will apply too high a weighting to that factor. Many representatives from smaller cities and towns fear that too high a weighting will be applied to the number of people affected, thus forcing more shipments through their communities.

While I don’t believe that a weighting system can be developed that will assuage the concerns of everyone involved, I do believe that it is imperative that there be a public discussion about the weighting system and that every effort should be made to develop a consensus on the relative weighting of the factors used in the model development.

PHMSA punted on this when they took the administratively easy way out and allowed each railroad to develop their own risk/benefit rating system. It took the burden off the agency and ensured that there would little acceptance of the methodology used. But to be fair to that agency, this is at heart a political decision and executive branch agencies have a poor record in handling political decisions. That is a responsibility more appropriately handled by Congress.

I applaud the railroad industry’s action in taking the initiative to develop a software tool to make these TIH routing assessments. I am happy to see DOT and DHS providing funding for that development. But, before that software system is put into use, there needs to be a public discussion on the relative weighting of the factors that go into that analysis. The transportation committees in both the House and Senate need to take this matter up at their earliest convenience.

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