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1 SUMMARY Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials Introduction The safe transport of hazardous materials (HazMat) throughout America's transporta- tion infrastructure (to include points of origin and destination) is imperative to a safe and economically robust society. The security of the nation's HazMat freight in all transporta- tion modes relies on a layered, multi-faceted security program. This comprehensive system is a constant monitor of the many areas, modes, and vehicles involved in HazMat trans- portation. One important part of this comprehensive security system is credentialing. Secu- rity credentials play an important role in ensuring security by vetting those individuals working with, or in support of, HazMat transport. This research project was designed to understand the current security credentialing system within the HazMat transportation system. Further- more, it was to explore the issues within the credentialing system and, if feasible, evaluate options for a consolidated credential. Research Approach The research team used an evolutionary approach to this project in which each task pro- vides the foundation for the following tasks. The research team evaluated each credential at its most basic level to determine the elements that make up the credential and the creden- tialing process. This elemental analysis approach provided the data blocks necessary for gen- erating and evaluating consolidated credential options in Phase II. The research team performed the following tasks during Phase I: · Task 1. Identify credentials and credential elements. The research team used a combination of credentials, credential applications, and lit- erature searching to identify both the credentials and the credential elements. · Task 2. Determine time and costs associated with each credential. To accomplish Task 2, a questionnaire was designed to collect empirical data related to the time to acquire each credential. This questionnaire was an online survey posted for approximately 10 weeks. Credential cost data were acquired from issuing agency Web sites and discussion with issuing agency representatives. · Task 3. Understand the regulatory, policy, and programmatic implications for each credential. Regulatory analysis data collection focused on the Code of Federal Regulations, the United States Code, the Federal Register, and issuing agency Web sites. The research team also contacted the issuing agencies for clarification when necessary. · Task 4. Determine the feasibility of a consolidated credential for persons who transport hazardous materials.
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2 The research team used the strengths, weaknesses, opportunities, and threats (SWOT) analysis framework to determine the feasibility of a consolidated credential approach. Both a consolidated credential approach and a non-consolidated credential approach were analyzed from the perspectives of security and cost-effectiveness. In Phase II, the research team developed four options for consolidating the credentials, based on the credentials deemed as candidates for consolidation in Phase I. Each of the four options was evaluated for potential as a long-term, broadly applicable consolidated creden- tial. This evaluation considered the unique elements and background check processes of the credentials comprising each option. Further analysis considered the policy and implemen- tation issues associated with consolidating security credentials. Findings The credential synthesis and elemental analysis, time and cost analysis, and regulatory analysis resulted in the identification of 19 credentials required of persons who transport hazardous materials: · Transportation Worker Identification Credential (TWIC); · Merchant Mariner License (MML); · Merchant Mariner Document (MMD); · Merchant Mariner Credential (MMC); · Standards of Training, Certification, and Watchkeeping for Seafarers (STCW); · Florida Uniform Port Access Credential (FUPAC); · Local Port IDs; · Security Identification Display Area (SIDA) badge; · Pilot's License; · e-RAILSAFE; · Engineer's License · Commercial Driver's License with HazMat Endorsement (CDL-HME); · Free and Secure Trade (FAST) card; · United States Postal Service (USPS) credential; · NEXUS; · Secure Electronic Network for Travelers Rapid Inspection (SENTRI); · U.S. passport; · RAPIDGate; and · Common Access Card (CAC). All of the identified credentials were categorized as either safety credentials, security cre- dentials, or dual credentials by primary function or purpose. Credentials with a primary pur- pose of validating the credential-holder's skill set were deemed safety credentials. Credentials whose primary function is to vet the credential-holder and confirm identity were deemed security credentials. Those credentials that functioned as a secure form of identification while ensuring that the credential-holder possesses the necessary skills were deemed dual credentials. Four safety credentials (i.e., MML, STCW, Pilot's License, and Engineer's License) were not carried on through the analysis because the consolidation of skill requirements was infeasible. Two security credentials (i.e., e-RAILSAFE and RAPIDGate) were identified by Task 2 questionnaire responses. These two credentials are administered by private compa- nies, thus they were not considered in any analyses due to being outside the scope of the project. Although FUPAC has broader applicability than most Port IDs due to acceptance
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3 at all ports throughout Florida, it was ultimately treated as a Local Port ID. All Local Port IDs were dropped from further analysis because the Local Port IDs are controlled by the individual port authorities and were deemed too varied to aggregate elemental data in a meaningful way. Therefore, the elemental and cost analyses included 9 security credentials and 2 dual creden- tials, for a total of 11 credentials (i.e., CAC, CDL-HME, FAST, MMD, MMC, NEXUS, pass- port, TWIC, SENTRI, SIDA, and USPS) that were deemed candidates for total consolidation. Elemental analysis of the 11 credentials resulted in the identification of 91 elements. The results were split into requirements-to-obtain credential (i.e., those pieces of information necessary to get the credential) and attributes (i.e., those pieces of information provided by the credential). There were 64 unique requirements-to-obtain elements and 27 unique attribute elements. All 11 candidate credentials shared five of the requirements-to-obtain elements, and three attribute elements. Seven of the requirements-to-obtain elements and four of the attribute ele- ments were applicable to over 90% of the credentials. In all, 25 elements (10 attribute elements and 15 requirements-to-obtain elements) apply to over 50% of the candidate credentials. The 11 candidate credentials ranged in cost from $50.00 (for the FAST and NEXUS creden- tials) to $132.50 (for the TWIC). The CDL-HME is issued by each state and the District of Columbia, with unique costs in each location ranging from a low of $107.25 (North Dakota) to a high of $326.25 (New York). The questionnaire resulted in 378 respondents over a 10-week collection period. Respon- dents ranged in age from less than 25 to 74 years old. The largest percentage (41%) fell within the bracket of 45 to 54 years old. Approximately 33% of respondents have been involved in the transportation of hazardous materials for more than 25 years. Of the responses received, 323 respondents held a CDL-HME, 247 respondents held a TWIC, and 52 respondents held a FAST card. No other credential was identified as being held by more than 10 respondents. The respondents reported that the time to acquire a credential ranged from less than 2 weeks to more than 16 weeks. The largest percentage (34%) identified that their time to acquire was between 2 and 4 weeks. Eighty-two percent of the respondents reported acquiring their cre- dential in less than 8 weeks. When questioned on their perception related to the time to acquire credentials on a five-point Likert-type scale (possible responses being way too short, too short, about right, too long, and way too long), 40% thought the time was about right. Approximately 39% thought the time to acquire was too long. In addition, 63% of respondents reported that it took less than 2 hours to complete the application for the credentials they held. Seventy-five percent of respondents reported that the time to complete the credential application was about right. With regard to physically acquiring the credentials, 75% of respondents reported that it took less than 2 hours to pick up their credentials. Sixty-four percent of respondents felt that the time to physically acquire the credentials was about right. A SWOT analysis was done from both a security perspective and a cost-effectiveness per- spective on both a consolidated credential approach and a non-consolidated credential approach. The security perspective SWOT analysis identified eight strengths and opportu- nities for a consolidated credentialing approach including · Provides one credential for end-user, · Has uniform look and design on the credential, · Ensures a minimum threshold for security, · Simplifies training for security personnel, · Simplifies "threats to mitigate" list, · Ensures only one issuing agency to notify if problems arise, · Fosters ability to quickly adapt policy for new threats, and · Enables better tracking of applicants.
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4 The security perspective SWOT analysis also identified five weaknesses and threats for a consolidated credentialing approach including · Institutional resistance, · State and federal legislative actions required, · Increased ability to abuse/misuse, · Decreased resolution with regard to the "threats to mitigate" list, and · International issues. The cost-effectiveness perspective SWOT analysis yielded four strengths and opportuni- ties related to the consolidated credential approach, including · Eliminates redundancies for the issuing agencies, · Eliminates redundancies for the credential users, · Increases availability of enrollment centers, and · Decreases training requirements for security personnel. The cost-effectiveness perspective SWOT analysis also identified the following weakness related to the consolidated credential approach, including · Requires new or additional technology. The SWOT analysis of a non-consolidated credential approach was done from both a security perspective and a cost-effectiveness perspective. The security perspective SWOT analysis identified two strengths and opportunities for a non-consolidated credential approach including · Provides tailored credentialing and · Enables focused applicant assessment. Six weaknesses and threats also were identified, including · Inconsistent vetting processes, · Re-vetting of the same people, · Inefficient information and data collection, · Data collection or processing errors, · Complexity of information sharing, and · Variance in credential appearances. In the same manner as the consolidated credential approach, a SWOT analysis was done from a cost-effectiveness perspective for the non-consolidated approach. This SWOT analysis did not identify any strength or opportunity, but it did identify four weaknesses and threats, including · Increases administrative costs, · Requires multiple enrollment centers and forms, · Requires multiple credential costs, and · Requires more training for facility security personnel. The collective results of the SWOT analysis indicate that a consolidated credential approach would be desirable as compared to a non-consolidated approach. Additionally, the results of
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5 the SWOT analysis are the foundation on which a consolidated credentialing system should be designed. A consolidated credential approach should take advantage of the existing strengths while exploiting the identified opportunities where possible and, at the same time, mitigate the weaknesses and focus on preventing the threats. The findings of the Elemental Analysis, the Time and Costs Analysis, the Regulatory Analysis, and the SWOT Analysis indicated that the consolidation of several security creden- tials required of persons who transport hazardous materials was feasible, including: TWIC, MMD, SIDA, USPS, and CAC. Based on the Phase I data collection efforts, the use cases, and technical advisory group (TAG) input, four consolidated credential options were developed. These consolidation options included · Option 1--TWIC; · Option 2--TWIC, MMD, SIDA, USPS, and CAC; · Option 3--TWIC and MMD; and · Option 4--TWIC, SIDA, CAC, and MMD. These options were then evaluated through assessment of their collective elements and background check processes. The credential combination with the most promise for broad applicability would be the option with the greatest number of unique elements. This assumes each element is necessary for each credential, and functionality would be limited without a given element. The comparison of these options did, however, provide some perspective as to the relative differences between them. Option 1 was, in fact, not a consolidated effort, but more of an evaluation of one credential (TWIC) as it compares to the other consolidated efforts. This provided a lower bounding of the unique elements necessary to create a transporta- tion security credential. Option 2 included all credentials deemed feasible for consolidation providing an upper bounding of unique elements. Option 3 consisted of those credentials (deemed feasible for consolidation) specific to the marine mode and allowed for evaluation of the elemental variance for consolidating within one mode. Option 4 consisted of all cre- dentials determined feasible for consolidation excepting the USPS credential. It was deter- mined that this credential was reported infrequently and did not appear to play a major role in the transportation of hazardous materials. Therefore, Option 4 was used to evaluate the impact of the USPS credential on the set of elements and associated background checks for consolidation. Evaluation of the background check process was similar and, in fact, was evidence of even greater alignment across all options. This near harmony of already existing processes indi- cates a high chance of success in eliminating redundancy as it relates to security credential background check processes. This evaluation did not consider issues of implementation or legislative impetus associ- ated with the consolidation process. These issues were reviewed independently using a mul- tiple-perspective analysis. This analysis considered the challenges associated with policy implementation as related to the consolidation of security credentials for persons who trans- port hazardous materials. Conclusions There are a number of redundant elements within the HazMat transportation worker security credentialing system. For at least several credentials (e.g., TWIC, MMD, SIDA, USPS, and CAC) consolidation is a feasible alternative. However, there is a significant amount of information that must be fully understood, and it is imperative to gain stakeholder input from all levels. The development and implementation of a consolidated security credential will
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6 require the preservation of unique features of the individual credential while creating a universally applicable credential (within the HazMat transportation system). The research also suggests that consolidation of background checks (the vetting processes) could be achieved and may present an intermediate alternative while still exploring the con- solidation of full credentials. The majority of the credentials identified as security credentials for transporting hazardous materials require a very similar background investigation. Through data-sharing agreements and standardization of the adjudication process, a streamlined back- ground investigation for these credentials could be achieved. This alternative also would require a standardization of the disqualifying offenses. It is recommended that further research be done to completely identify and understand the costs and benefits associated with the consolidation process. This cost information is imperative to truly determine the value of a consolidated option in regard to the existing credentialing system. Furthermore, it is recommended that a separate effort be undertaken to focus on the potential standardization of background evaluations for credentials. This effort appears most promising in increasing efficiency and decreasing costs in the short term.