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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
×
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Suggested Citation:"Chapter 3 - Findings and Applications." National Academies of Sciences, Engineering, and Medicine. 2011. Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials. Washington, DC: The National Academies Press. doi: 10.17226/14565.
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15 Identified Credentials The literature search, in combination with TAG advise- ment, resulted in identification of 19 credentials related to persons who transport hazardous materials. For many of these credentials, their applicability extends beyond the transport of hazardous materials; however, each credential identified was required of a person who transported haz- ardous materials across the various transportation modes. Two of the credentials (i.e., e-RAILSAFE and RAPIDGate) are administered by private entities but were included in Table 3-1 because they were identified by the Task 2 ques- tionnaire. These two credentials were not considered in any further analyses. Table 3-1 lists the credential name, acronym or abbreviation (if applicable), issuing agency, and primary transportation mode (other transportation modes may be applicable in some cases). By transportation mode, seven credentials were designated for marine, seven credentials were designated for highway, two credentials were designated for air, and two credentials were designated for rail. One credential, the U.S. passport, was considered equally applicable to all transportation modes. Fig- ure 3-1 shows the chronological progression of the credentials based on the first year of issuance (or, in some cases, the date of legislation first mentioning the program). Due to multiple authorities issuing U.S. passports, in 1856 Congress enacted legislation providing full authority to the State Department to be the only legal entity to issue U.S. pass- ports.(7) In 1938, the United States Merchant Marine Acad- emy was founded and became the first federal government entity to issue the Merchant Mariner License. By 1941, the Defense Entry and Departure Act required U.S. citizens to use a passport when traveling abroad. In 1978 in London, the Inter- national Maritime Organization (IMO) adopted the Interna- tional Convention on Standards of Training, Certification, and Watchkeeping for Seafarers (STCW). The IMO adopted a major STCW revision in 1995. The Commercial Driver’s License (CDL) was first intro- duced in 1986 through the Commercial Motor Vehicle Safety Act of 1986 (CMVSA), and did have restrictions on the opera- tion of commercial motor vehicles (CMVs) transporting haz- ardous materials. These restrictions were knowledge- and capability-based, and did not include a threat assessment. Although the CMVSA was enacted in 1986, it was not until 1992 that drivers were required to have a CDL to operate some vehicles.(8) SENTRI was first introduced in 1995 as a method of increasing security and efficiency at border crossings. The NEXUS program was next introduced in 2002 as a highway- specific program for pre-screening individuals for greater effi- ciency at border crossings. In the same year, SIDA badges were introduced as a measure of security in airports. Several acts of legislation in 2002 added new credentials or additional security programs to existing credentials, including the USA PATRIOT Act and the MTSA of 2002 (refer to the regulatory analysis sec- tion for specifics). In 2003, to acquire an HME for a CDL began requiring a full security threat assessment. In 2004, USPS pub- lished a management instruction indicating the necessary steps for screening highway transportation contract employ- ees.(9) Also in 2004, the Florida State Legislature passed a bill enacting the FUPAC (Title 22 Ports and Harbors, Ch. 311, Sec. 311.125 Florida Statutes). The FAST program and card were first implemented in 2005, based on the Trade Act of 2002. The FAST card is designed to add a pre-screened layer of security to cross-border highway freight transportation.(10) In 2006, the U.S. military began issuing the CAC to contractors accessing their facilities, including truck drivers who may be hauling hazardous materials. By 2007, the NEXUS program was extended to include air transportation, although the intent of the program was relatively unchanged. In 2007, the SIDA badge vetting process was changed to include the TSA security threat assessment prior to issuing a badge (as opposed to the original process of the airport issuing the badge before provid- ing TSA with the information to perform the security threat assessment).(11) By 2009, both the MMC and the TWIC had C H A P T E R 3 Findings and Applications

been fully implemented.(12,13) The legislative authority for both began in 2002 with the MTSA and continued with the Security and Accountability for Every Port Act of 2006 (SAFE Port Act). The timeline provides a visual representation of not only the time frame within which these credentials were developed and implemented, but also a reflection of their functionality and changes to the security and communication environments. Prior to 1995, the majority of credentials were designed to ensure that the credential-holder possessed the necessary capa- bilities (e.g., MML, STCW, and CDL). The drastic increase in the number of credentials after 1995 reflects, at least in some part, the technological advances of communication (e.g., the Internet), data collection techniques (e.g., online applications, digital photographs, digital fingerprints, etc.), and data storage capabilities (e.g., database structures, encryption software, 16 Figure 3-1. Credential timeline. Table 3-1. Identified credentials related to hazmat transportation workers. Name Acronym Issuing Agency Mode Transportation Worker Identification Credential eniraMASTCIWT Merchant Mariner License MML United States Coast Guard (USCG) Marine Merchant Mariner Document eniraMGCSUDMM Merchant Mariner Credential eniraMGCSUCMM Standards of Training, Certification, and Watchkeeping for Seafarers STCW International Maritime Organization/USCG Marine Florida Uniform Port Access Credential FUPAC Florida Department of Highway Safety and Motor Vehicles Marine Local Port IDs N/A Local Port Authority Marine Security Identification Display Area Badge SIDA Individual Airport Authorities Air Pilot’s License riAAAFA/N e-RAILSAFE N/A e-VERIFILE.COM, Inc. Rail Engineer’s License liaRARFA/N Commercial Driver’s License with HazMat Endorsement CDL-HME States/TSA Highway Free and Secure Trade Card FAST Customs and Border Protection (CBP) Highway United States Postal USPS United States Postal Service (USPS) Highway Service Credential NEXUS yawhgiH PBC A/N Secure Electronic Network for Travelers Rapid Inspection yawhgiH PBC IRTNES U.S. Passport N/A U.S. State Department All RAPIDGate N/A Eid Passport, Inc. Highway Common Access Card CAC Department of Defense Highway 2003 Passport Passport 2002 CAC SIDA NEXUS USPS CDL 1850 1940 0102000259910991589108910591 200 4 200 7 SIDA NEXUS TWIC HME MMC 2009 FAST 2005 SENTRI 2002 FUPAC MML STCW

and secure network connections). The number of credentials developed since 2002 is, to some extent, the result of the flurry of legislation resulting from the terrorist attacks of September 11, 2001. Security credentials became the regulatory method of effecting access control. Credential Categorization Credentials were then categorized based on their primary purpose of security (i.e., confirms that a person does not pose a security threat, establishes that a person possesses lawful sta- tus in the United States, and verifies identity) or safety (i.e., ver- ifies a person’s “skill” qualifications). Figure 3-2 illustrates this segregation of the credentials into the categories of security or safety. Of these credentials, 13 were designed primarily to function as a security authentication for the credential- holder, 4 were designed primarily to certify the skill qual- ifications of the credential-holder (i.e., the MML, STCW, Pilot’s License, and Engineer’s License), and 2 function as both a means of security and safety (i.e., the CDL-HME and MMC). The HazMat endorsement for the CDL requires a threat assessment (14), thus vetting the credential-holder from a security perspective. The MMC is a consolidation of the MMD, MML, and STCW.(12) It requires both a demonstra- tion of the abilities of the credential-holder (MML and STCW) and a determination of the perceived security risk (MMD) of the credential-holder. This research effort was tasked with evaluating security credentials for persons who transport hazardous materials. As such, those credentials without a primary purpose of vet- ting the credential-holder and communicating the informa- tion necessary to determine the credential-holder’s validity were dropped from the remaining analysis efforts. These safety credentials were simply outside the scope of this project. Requirements-to-Obtain Elements During the application process, the issuing agencies require those seeking to obtain a security credential to submit various types of information (e.g., name, address, Social Security Num- ber). These requirements to obtain were gathered through the individual applications and organized into several matrices to illustrate overlap or uniqueness among the various security credentials. These matrices were grouped by transportation mode to aid in identifying common requirements. Due to the number of identified requirements to obtain, the results were split into two matrices. Table 3-2 illustrates all requirements to obtain that apply to more than one credential. There are 34 singularly applicable requirements to obtain (that is, applica- ble to only one credential) that are tabulated in Appendix B. There are 30 requirements to obtain that apply to more than one credential. An applicant must submit his or her full name, date of birth, citizenship information, address, and undergo a security threat assessment for all of the identified security cre- dentials. Additionally, two of the requirements are applicable to 91% of the identified credentials: place of birth (not appli- cable to the CDL-HME) and fingerprinting (not applicable to the passport). In total, 16 requirements apply to the majority (>50%) of the identified credentials, including the 9 require- ments previously listed: sex (82% applicable), Social Security Number (73% applicable), phone number (64% applicable), aliases (64% applicable), height (55% applicable), eye color (55% applicable), hair color (55% applicable), employer name (55% applicable), and e-mail address (55% applicable). In total, there are 64 different requirements of an applicant to obtain each of the 11 identified security credentials. Only 25% of the requirements apply to the majority (>50%) of creden- tials, and only 8% of the requirements are universally applica- ble across all 11 identified credentials. Table 3-3 groups all background-check processes into the security threat assessment category. This was done to simplify the table for comparison purposes. However, this is an impor- tant aspect of the security credentials, especially with regard to duplication of effort and redundant costs (refer to the cost analysis section). Table 3-3 specifies the background check processes for each credential. The fingerprint-based criminal records check refers to the background check performed by the Federal Bureau of Inves- tigation (FBI) using the National Crime Information Center (NCIC). Regardless of the issuing agency, the FBI performs this portion of the investigation and then provides the relevant data to the issuing agency (or adjudicating organization). A name-based investigation of relevant databases includes non- fingerprint criminal history record checks (e.g., U.S. passport), and a review of the Terror Watch List (e.g., TWIC, MMC, and HME) maintained by DHS. This could also include other data- bases as the issuing agency may deem fit for a given circum- stance. The MMD requires a drug test as part of the application 17 Figure 3-2. Credential categorization.

18 Credential Applicable Mode Fu ll N a m e D at e o f B irt h Ci tiz en sh ip In fo rm a tio n A dd re ss Se cu rit y Th re a t A ss e ss m e n t Pl a c e o f B irt h Fi n ge rp rin tin g Se x So ci a l S e cu rit y N um be r Ph o n e N u m be r A lia se s H ei gh t Ey e Co lo r H a ir Co lo r Em pl o ye r' s N a m e W ei gh t Em a il A dd re ss Em pl oy e r' s A dd re ss O cc u pa tio n A dd re ss H ist o ry Em pl o ye r' s Ph o n e N u m be r Em pl oy m en t H ist o ry V isi o n Te st N a tio n a l D riv er s R eg ist ry Ch e ck Fa x N u m be r N ex t o f K in Ch a ra ct e r R e fe re n ce s H ea rin g Te st M ed ic a l o r Ph ys ic a l E x a m N ic kn a m e SIDA Air Passport All TWIC Marine MMD Marine MMC Marine CDL-HME Highway FAST Highway USPS Highway NEXUS Highway SENTRI Highway CAC Highway Table 3-2. Requirements to obtain credential. TW IC H M E M M D M M C SI D A FA ST N EX U S SE N TR I U SP S Pa ss po rt CA C Fingerprint-Based Criminal Records Check Name-Based Relevant Database Check Drug Test National Driver Register Check Interview Table 3-3. Credential background checks. process, and results of the test are included in the adjudication process. A review of the National Driver Register is required for the MMD, MMC, and USPS credentials. In each case, one’s driving record can influence the application process (refer to the disqualifying offenses section). Finally, an interview with issuing agency personnel is required for the three CBP-issued credentials (FAST, NEXUS, and SENTRI). It is important to note that the agencies performing the background checks remain relatively consistent; for instance, the FBI is responsible for the criminal history records checks for each of the credentials (name- and fingerprint-based). For each credential requiring a review of the Terror Watch List, as stated, there is only one clearinghouse for this information via the FBI. The key difference for many of the credentials is the process of adjudication. Each issuing agency receives the results of all background check processes and determines the appli- cant’s eligibility for the credential. Attribute Elements Once the credential is obtained, there are distinctive attrib- utes on, or within, each credential that are used by both secu- rity personnel and others to authenticate the identity and intentions of the credential-holder. These attributes were gath- ered by examining actual photo renderings, or textual descrip- tions, of credentials. Table 3-4 lists those elements that are displayed on, or contained within, the credential. Where each attribute applies to a given credential there is a correspon- ding mark noting the relationship. This attribute matrix in Table 3-4 is grouped by transportation mode to provide a

graphic representation of the similarities among credentials within a particular mode. There are 27 unique attributes identified from 11 creden- tials. Three attributes, full name, date of expiration, and pho- tograph, are common to all credentials. Ten of the attributes apply to the majority (>50%) of the credentials. In addition to the three previously stated, the other seven include: tamper- resistant features (91% applicable), unique serial number (64% applicable), date of birth (64% applicable), citizenship (55% applicable), sex (55% applicable), endorsements (55% applicable), and bar code (55% applicable). Table 3-5 provides a brief overview of the technology types and associated information contained within the specified cre- dentials. In some cases (e.g., TWIC), the credentials have been designed to allow for additional information to be stored on the credential. Disqualifying Offenses Disqualifying offenses are those offenses that would bar an applicant from qualifying for a credential. In many cases these are specific criminal violations that are stated as such. In some cases, the disqualifying offenses are related to monetary infrac- tions, applicant flight risk, or suspicion of an applicant based on intelligence information. The disqualifying offenses are grouped by issuing agency rather than credential; this is to provide an understanding of the threats, or perceived threats, for each issuing agency. Again, a list of the issuing agencies can be found in Table 3-1 of this report. TSA (15–19) TWIC • Permanent Disqualifying Criminal Offenses—no time limit – Espionage or conspiracy to commit espionage; – Sedition or conspiracy to commit sedition; – Treason or conspiracy to commit treason; – A crime listed in 18 U.S.C. Chapter 113B—Terrorism or conspiracy to commit such a crime; – A crime involving a transportation security incident; – Improper transportation of a hazardous material; – Unlawful possession, use, sale, distribution, manufac- ture, purchase, receipt, transfer, shipping, transporting, import, export, storage of or dealing in an explosive or explosive device; – Murder; – Threat or maliciously conveying false information know- ing the same to be false, concerning the deliverance, place- ment, or detonation of an explosive or other lethal device in or against a place of public use, state or government facil- ity, a public transportation system, or an infrastructure facility; – Certain Racketeer Influenced and Corrupt Organizations (RICO) Act violations (in which the predicate act is one of the permanently disqualifying crimes); – Conspiracy or attempt to commit crimes in 49 CFR Part 1572 Subpart B Paragraph (a)(5)—(a)(10); • Interim Disqualifying Criminal Offenses—Conviction within 7 years, or release from incarceration within 5 years, 19 Credential Applicable Mode Fu ll N am e D at e o f E xp ira tio n Ph ot o gr ap h Ta m pe r- re sis ta n t f ea tu re s U ni qu e Se ria l N u m be r D at e o f B irt h Ci tiz en sh ip Se x En do rs em en ts B ar C o de Si gn at u re If fo u n d A u th o riz at io n A ge n cy Is su in g Lo ca tio n /B ra n ch R ad io Fr eq u en cy Id en tif ic at io n D at e o f I ss ue A dd re ss Ey e C o lo r H ei gh t Em pl o ye r Pl ac e o f B irt h H ai r C o lo r W ei gh t D u al In te rfa ce IC C So cia l S ec u rit y N u m be r M ag ne tic St rip A cc es s Le v el SIDA Air Passport All TWIC Marine MMD Marine MMC Marine CDL-HME Highway FAST Highway USPS Highway NEXUS Highway SENTRI Highway CAC Highway Table 3-4. Credential attributes matrix.

of application; includes wants and warrants associated with the following crimes: – Unlawful possession, use, sale, manufacture, purchase, distribution, receipt, transfer, shipping, transporting, import, export, storage of or dealing in a firearm or other weapon; – Extortion; – Dishonesty, fraud, or misrepresentation, including iden- tity fraud and money laundering; – Bribery; – Smuggling; – Immigration violations; – Distribution, possession with intent to distribute, or importation of a controlled substance; – Arson; – Kidnapping or hostage-taking; – Rape or aggravated sexual abuse; – Assault with intent to murder; – Robbery; – Lesser violations of the RICO Act; or – Conspiracy or attempt to commit crimes in 49 CFR 1572 Subpart B Paragraph (b). USCG (20) MMC Table 3-6 illustrates the disqualifying offenses for the MMC. Individual States (21–22) CDL-HME The TSA performs the security threat assessment for HMEs; thus, it is the same for all states. • Permanently Disqualifying Criminal Offenses—Applicants are permanently disqualified from holding an HME on a state-issued CDL if convicted or found not guilty by rea- son of insanity for any of the following crimes: 20 noitamrofnIygolonhceTlaitnederC TWIC Smart Card • Dual interface integrated circuit chip (ICC) • Magnetic strip • Bar code Photograph Fingerprints Personal ID number Meets FIPS 201-1 & ANSI 322 Standards Durability tests performed: -Flexure -U/V exposure -Humidity -Surface abrasion -Fading -Laundry test sserdda,emaNedocrabD-3EMH-LDC Endorsements, restrictions Birth date, expiration date ID number Sex, eye color, height There may be some variance due to issuing state. SIDA Magnetic strip 26-bit encryption. Different badge colors for levels of access. Embedded hologram. Contains a 6-digit number defining levels of access. FAST NEXUS SENTRI An antenna and integrated-circuit radio frequency identification (RFID) containing a unique number to verify the identity of the bearer to border protection officers. Unique serial number The number is read wirelessly and sent to back- end computer systems. The systems retrieve personally identifiable information. (The unique number does not in itself contain any personally identifiable information.) The systems involved are law enforcement databases, watch lists, and credential application information. Passport Embedded Electronic Chip (RFID) New ePassports contain an embedded chip that is a duplicate electronic copy of all information from the data page—name, date of birth, place of birth, issuing office, and a digitized photo. Table 3-5. Credential technology description.

– Espionage;* – Sedition;* – Treason;* – A crime listed in 18 U.S.C. Chapter 113B—Terrorism, or a state law that is comparable;* – Bomb threats; – Crime involving a transportation security incident; – Improper transportation of hazardous materials under 49 U.S.C. 5124 or a comparable state law; – Unlawful possession, use, sale, distribution, manufac- ture, purchase, receipt, transfer, shipping, transporting, import, export, storage of or dealing in an explosive or explosive device; – Murder; 21 Crime1 Minimum Maximum Assessment Periods for Officer and Rating Endorsements Year(s) Years Crimes against Persons Homicide (intentional) 7 20 Homicide (unintentional) 5 10 Assault (aggravated) 5 10 Assault (simple) 1 5 Sexual assault (rape, child molestation) 5 10 Robbery 5 10 Other Crimes against Persons2 Vehicular Crimes Conviction involving fatality 1 5 Reckless driving 1 2 Racing on the highways 1 2 Other vehicular crimes Crimes against Public Safety Destruction of property 5 10 Other crimes against public safety Dangerous Drug Offenses3,4,5 Crime Minimum Maximum Trafficking (sale, distribution, transfer) 5 10 Dangerous drugs (use or possession) 1 10 Other dangerous drug convictions6 Assessment Periods for Officer Endorsements Only Criminal Violations of Environmental Laws Criminal violations of environmental laws involving improper handling of pollutants or HazMat 1 10 Crimes against Property 013yralgruB 53ynecraL ytreporptsniagasemircrehtO Notes: 1Convictions of attempts, solicitations, aiding and abetting, accessory after the fact, and conspiracies to commit criminal conduct listed in this table carry the same minimum and maximum assessment periods provided in the table. 2Other crimes will be reviewed by the USCG to determine the minimum and maximum assessment periods depending on the nature of the crime. 3Applicable to original applications only. Any applicant who has ever been the user of, or addicted to the use of, a dangerous drug shall meet the requirements of Paragraph (f) of 46 CFR §10.211. Note: Applicants for reissue of an MMC with a new expiration date, including a renewal or additional endorsement(s), who have been convicted of a dangerous drug offense while holding a license, MMC, MMD, STCW endorsement or Certificate of Registry (COR), may have their application withheld until appropriate action has been completed by the USCG under regulations that appear in 46 CFR Part 5 governing the administrative actions against merchant mariner credentials. 4The USCG may consider dangerous drug convictions more than 10 years old only if there has been another dangerous drug conviction within the past 10 years. 5Applicants must demonstrate rehabilitation under Paragraph (I) of this section [§10.211 (46 CFR)], including applicants with dangerous drug use convictions more than 10 years old. 6Other dangerous drug convictions will be reviewed by the USCG on a case-by-case basis to determine the appropriate assessment period depending on the nature of the offense. Table 3-6. Disqualifying offenses for the MMC. *Not eligible for a waiver

– Violations of the RICO Act under 18 U.S.C. 1961, or a comparable state law, where violations consist of any of the permanent disqualifying offenses; or – Conspiracy or attempt to commit any of these crimes. • Interim Disqualifying Criminal Offenses—If convicted or found not guilty by reason of insanity within the previous 7 years, or released from prison in the last 5 years, for any of the following crimes: – Unlawful entry into a seaport; – Assault with intent to murder; – Kidnapping or hostage-taking; – Rape or aggravated sexual abuse; – Unlawful possession, use, sale, manufacture, purchase, distribution, receipt, transfer, shipping, transporting, delivery, import, export of or dealing in a firearm or other weapon; – Extortion; – Dishonesty, fraud, or misrepresentation, including identity fraud; – Bribery; – Smuggling; – Immigration violations; – Violations of the RICO Act under 18 U.S.C. 1961, or a comparable state law, other than any permanent disqual- ifying offenses; – Robbery; – Distribution of, intent to distribute, or importation of a controlled substance; – Arson; or – Conspiracy or attempt to commit any of these crimes. CBP (23–25) FAST, NEXUS, SENTRI • Disqualifying Offenses – Provided false or incomplete information on the appli- cation; – Have been convicted of a criminal offense; – Have a criminal conviction for which applicant received a pardon; – Have failed to obtain a waiver of inadmissibility to the United States when applicable; – Have been found in violation of customs or immigration law; – Fail to meet other requirements of the FAST Commercial Driver Program; – Will not lawfully reside in either Canada or the United States for the term of their NEXUS membership; – Are inadmissible to the United States or Canada under applicable immigration laws; – Have pending criminal charges to include outstanding warrants; – Have been found in violation of any customs, immigra- tion, or agriculture regulations or laws in any country; – Are subject of an ongoing investigation by any federal, state, or local law enforcement agency; – Are inadmissible to the United States under immigration regulation, including applicants with approved waivers of inadmissibility or parole documentation; or – Cannot satisfy the CBP of a low risk status or meet other program requirements. Individual Airport Authorities (26) SIDA • Disqualifying Offenses – Forgery of certificates, false marking of aircraft, and other aircraft registration violations (49 U.S.C. 46306); – Interference with air navigation (49 U.S.C. 46308); – Improper transportation of a hazardous material (49 U.S.C. 46312); – Aircraft piracy (49 U.S.C. 46502); – Interference with flight crew members or flight atten- dants (49 U.S.C. 46504); – Commission of certain crimes aboard aircraft in flight (49 U.S.C. 46506); – Carrying a weapon or explosive aboard aircraft (49 U.S.C. 46505); – Conveying false information and threats (49 U.S.C. 46507); – Aircraft piracy outside the special aircraft jurisdiction of the U.S. (49 U.S.C. 46502[b]); – Lighting violations involving transporting controlled substances (49 U.S.C. 46315); – Unlawful entry into an aircraft or airport area that serves air carriers or foreign air carriers contrary to established security requirements (49 U.S.C. 46314); – Destruction of an aircraft or aircraft facility (18 U.S.C. 32); – Murder; – Assault with intent to murder; – Espionage; – Sedition; – Kidnapping or hostage-taking; – Treason; – Rape or aggravated sexual abuse; – Unlawful possession, use, sale, distribution, or manu- facture of an explosive or weapon; – Extortion; – Armed or felony unarmed robbery; – Distribution of, or intent to distribute, a controlled substance; – Felony arson; – Felony involving a threat; – Felony involving 22

 Willful destruction of property;  Importation or manufacture of a controlled substance;  Burglary;  Theft;  Dishonesty, fraud, or misrepresentation;  Possession or distribution of stolen property;  Aggravated assault;  Bribery; or  Illegal possession of a controlled substance punishable by a maximum term of imprisonment of more than one year; – Violence at international airports (18 U.S.C. 37); or – Conspiracy or attempt to commit any of the criminal acts listed herein. U.S. Department of State (27–28) U.S. Passport • Disqualifying Offenses – The department may not issue a passport, except a pass- port for direct return to the United States, in any case in which the department determines or is informed by com- petent authority that  The applicant is in default on a loan received from the United States under 22 U.S.C. 2671(b)(2)(B) for the repatriation of the applicant and, where applicable, the applicant’s spouse, minor child(ren), and/or other immediate family members, from a foreign country (see 22 U.S.C. 2671[d]); or  The applicant has been certified by the secretary of Health and Human Services as notified by a state agency under 42 U.S.C. 652(k) to be in arrears of child support in an amount determined by statute. – The department may refuse to issue a passport in any case in which the department determines or is informed by competent authority that  The applicant is the subject of an outstanding federal warrant of arrest for a felony, including a warrant issued under the Federal Fugitive Felon Act (18 U.S.C. 1073);  The applicant is subject to a criminal court order, con- dition of probation, or condition of parole, any of which forbids departure from the United States and the violation of which could result in the issuance of a federal warrant of arrest, including a warrant issued under the Federal Fugitive Felon Act;  The applicant is subject to a U.S. court order commit- ting him or her to a mental institution;  The applicant has been legally declared incompetent by a court of competent jurisdiction in the United States;  The applicant is the subject of a request for extradition or provisional request for extradition that has been presented to the government of a foreign country;  The applicant is the subject of a subpoena received from the United States pursuant to 28 U.S.C. 1783, in a matter involving federal prosecution for, or grand jury investigation of, a felony;  The applicant is a minor and the passport may be denied under 22 CFR 51.28;  The applicant is subject to an order of restraint or apprehension issued by an appropriate officer of the U.S. Armed Forces pursuant to Chapter 47 of Title 10 of the U.S. Code;  The applicant is the subject of an outstanding state or local warrant of arrest for a felony; or  The applicant is the subject of a request for extradi- tion or provisional arrest submitted to the United States by a foreign country. – The department may refuse to issue a passport in any case in which:  The applicant has not repaid a loan received from the United States under 22 U.S.C. 2670(j) for emergency medical attention, dietary supplements, and other emergency assistance, including, if applicable, assis- tance provided to his or her child(ren), spouse, and/or other immediate family members in a foreign country;  The applicant has not repaid a loan received from the United States under 22 U.S.C. 2671(b)(2)(B) or 22 U.S.C. 2671(b)(2)(A) for the repatriation or evacua- tion of the applicant and, if applicable, the applicant’s child(ren), spouse, and/or other immediate family members from a foreign country to the United States;  The applicant has previously been denied a passport under this section or 22 CFR 51.61, or the department has revoked the applicant’s passport or issued a limited passport for direct return to the United States under 22 CFR 51.62, and the applicant has not shown that there has been a change in circumstances since the denial, revocation, or issuance of a limited passport that warrants issuance of a passport; or  The secretary determines that the applicant’s activities abroad are causing, or are likely to cause, serious dam- age to the national security or the foreign policy of the United States. – The department may refuse to issue a passport in a case in which the department is informed by an appropriate foreign government authority or international organiza- tion that the applicant is the subject of a warrant of arrest for a felony. – The department may refuse to issue a passport, except a passport for direct return to the United States, in any case in which the department determines or is informed by a 23

competent authority that the applicant is a minor who has been abducted, wrongfully removed or retained in violation of a court order or decree, and return to his or her home state or habitual residence is necessary to per- mit a court of competent jurisdiction to determine cus- tody matters. – A passport may not be issued in any case in which the department determines or is informed by a competent authority that the applicant is subject to imprisonment or supervised release as the result of a felony conviction for a federal or state drug offense if the individual used a U.S. passport or otherwise crossed an international border in committing the offense, including a felony conviction arising under  The Controlled Substances Act (21 U.S.C. 801 et seq.) or the Controlled Substances Import and Export Act (21 U.S.C. 951 et seq.);  Any federal law involving controlled substances as defined in section 802 of the Controlled Substances Act (21 U.S.C. 801 et seq.);  The Bank Secrecy Act (31 U.S.C. 5311 et seq.) or the Money Laundering Act (18 U.S.C. 1956 et seq.) if the department is in receipt of information that supports the determination that the violation involved is related to illicit production of, or trafficking in, a controlled substance; or  Any state law involving the manufacture, distribution, or possession of a controlled substance. – A passport may be refused in any case in which the depart- ment determines or is informed by a competent author- ity that the applicant is subject to imprisonment or supervised release as the result of a misdemeanor convic- tion of a federal or state drug offense if the individual used a U.S. passport or otherwise crossed an international border in committing the offense, other than a first con- viction for possession of a controlled substance, including a misdemeanor conviction arising under  The federal statutes described in §51.61(a); or  Any state law involving the manufacture, distribution, or possession of a controlled substance. – Notwithstanding paragraph (a) of this section [22 CFR §51.61] the department may issue a passport when the competent authority confirms, or the department other- wise finds, that emergency circumstances or humanitar- ian reasons exist. USPS (9) Disqualifying Factors • Subject of an outstanding warrant; • Convicted of illegally using, possessing, selling, or transfer- ring controlled substances within the last 5 years; • Convicted of a felony criminal charge within the last 5 years; • Convicted of offenses involving dishonesty, moral turpi- tude, financial gain, or assault within the past 5 years; • On parole, probation, or under a suspended sentence for commission of a felony or any controlled substance charge; • Pending felony charges or any pending controlled sub- stance charge; • Has an established pattern of criminal conduct that could undermine the efficiency of the Postal Service or safety of its employees; or • Convicted of, under investigation for, or under indictment for stealing mail or other postal crimes. Time and Cost Analyses Time-to-Acquire Questionnaire Analyses The consolidated questionnaire became active on a com- mercial hosting Web site (SurveyMonkey) on April 20, 2010. The questionnaire was promoted to credential-holders via communications with TAG members, industry groups, labor organizations, and word-of-mouth recruitment. Data collec- tion lasted 10 weeks and is shown by respondents and mode in Figure 3-3. A total of 378 respondents completed the time- to-acquire questionnaire by June 30, 2010. Sample Demographics Respondents’ demographic information was collected. The demographic data included the respondents’ age, sex, expe- rience transporting hazardous materials, role in the trans- portation process, transportation mode, and credentials. The majority of respondents (95.3%; 304 respondents) were male; only 4.7% (15 respondents) were female. Most of the respon- dents were 45 to 54 years old (41.1%; 131 respondents), 55 to 64 years old (31%; 99 respondents), or 35 to 44 years old (18.8%; 60 respondents). The youngest respondents were under 25 years old (0.3%; 1 respondent) and 25 to 34 years old (3.4%; 11 respondents). The oldest respondents were 65 to 74 years old (5.3%; 17 respondents). There were no respon- dents who reported they were 75 years or older. However, 59 respondents failed to provide sex or age data. Respon- dents also were asked how long they had been involved with the transportation of hazardous materials. Of the 317 respon- dents who answered this question, 12.9% (41 respondents) had less than 5 years’ experience, 12.6% (40 respondents) had 5 to 9 years’ experience, 12% (38 respondents) had 10 to 14 years’ experience, 14.2% (45 respondents) had 15 to 19 years’ expe- rience, 15.5% (49 respondents) had 20 to 25 years’ experience, and 32.8% (104 respondents) had over 25 years’ experience. Respondents self-reported their roles in the transportation process. Respondents were asked to provide the title that best 24

described their role in the transportation of hazardous ma- terials. Of the 378 respondents, 307 provided answers to this question. Responses represented a wide range of professions (business owners, commercial truck drivers, port police) and supervisory responsibility (line workers such as railroad engi- neers, administrators in charge of port operations and secu- rity). Figure 3-4 provides a summary of the categories of roles that respondents indicated they held. Most respondents worked in the highway/tractor trailer mode (93.8%; 345 respondents). There were 12% (44 respon- dents) who worked in the marine mode, 8.4% (31 respon- dents) worked in the rail mode, and 5.7% (21 respondents) reported that they worked in the air mode. Please note that some respondents chose multiple modes, thus the totals sum to more than 100%. Questionnaire respondents were asked to indicate whether they held a number of credentials. Of the 364 respondents (out of 378 total respondents) who answered this question, 88.7% (323 respondents) held a CDL-HME and 67.9% (247 respon- dents) held a TWIC. The FAST credential was held by 14.3% (52 respondents), and 14.8% (54 respondents) reported hold- ing an “other” credential. Figure 3-5 provides a summary of the credentials held. Respondents were asked what other creden- tials were required for their jobs. Additionally, individuals were asked to provide feedback on the other credentials held. Fig- ure 3-6 illustrates those credentials for which individuals pro- vided additional feedback. Credentials also were examined by mode. Figures 3-7 through 3-10 provide a breakdown of cre- dentials held by mode. The majority of highway/tractor- trailer respondents held a CDL-HME and/or the TWIC. This is expected based on the nature of those credentials. Like- wise, marine respondents also held the FUPAC, MMC, MMD, and MML. Total Time to Obtain Credentials Figure 3-11 provides a summary of the total time respon- dents needed to obtain their credentials, from completion of the application process through physical receipt of the creden- tial. The majority of respondents completed the application process and received their credential within 2 months (81.5%). Respondents provided an assessment of the total time needed to complete the application process and receive their credentials. Almost 40% of respondents considered that the time needed to obtain the credential was adequate. However, a combined 59.3% believed that the process took too long (39.1%) or way too long (20.2%). Only six respondents (1%) believed that the process was too short (Figure 3-12). A crosstab of the number of respondents reporting too long, way too long, and times to obtain a credential can be found in Appendix D. Time to Complete Application Respondents were asked to provide an estimate of the amount of time it took to complete the application process (i.e., from the time they started the application to the time the application was provided to the credentialing agency). The majority of respondents (63.2%; 361 respondents) (Fig- ure 3-13) completed and submitted the application in less than 2 hours. However, 8.1% (46 respondents) indicated that 25 0 50 100 150 200 250 300 350 400 1 2 3 4 5 6 7 8 9 10 Pa rt ic ip an ts C om pl et in g Su rv ey Week of Data Collection Total Highway Unknown Rail Air Marine Figure 3-3. Data collection progress by mode.

26 Figure 3-5. Credentials held by respondents. 323 247 52 8 4 4 3 1 0 7 54 0 50 100 150 200 250 300 350 R es po ns e Co un t Credential Figure 3-4. Administrators’ roles in the transportation process. 1 2 2 3 3 4 5 5 5 5 12 25 30 53 152 0 50 100 150 200 Marine Engineer Government Agency Representatives N/A - Does Not Transport HM Locomotive Engineers Tankermen (Marine) Dispatchers Trucking Carriers Port Security/Escorts Private Security Contractors & Consultants Safety (No Further Clarification) Private Industry Owners or Managements Handling & Delivery of HazMat - Not Included Elsewhere Non-safety Managers, Directors, Supervisors Safety Managers, Directors, Supervisors Truck Drivers Response Count R es po nd en ts ' T itl es

27 Figure 3-6. Other credentials for which respondents provided feedback. Figure 3-7. Credentials held by air mode respondents. Figure 3-8. Credentials held by highway/ tractor-trailer respondents. 1 1 1 1 2 2 2 2 2 4 5 5 10 19 0 5 10 15 20 Canadian Petroleum Products Institute Card Picture ID Professional Driver State Driver's License CDL with Tank Endorsement Criminal History & Security Check DOT HazMat Training E-Railsafe and E-Safe No Current Credential/NA Port Authority Specific Certifications Customer or Company Specific Certifications Law Enforcement Officer or Law Enforcement Provided Certifications Government or Military Security Clearance or Certificate Passport 15 10 0 5 10 15 20 25 A ir M od e R es po ns e C ou nt 3 1 0 0 0 0 0 3 Credential 4 321 227 0 50 100 150 200 250 300 350 H ig hw ay /T ra ct or -T ra ile r M od e R es po ns e C ou nt 52 6 0 0 0 1 0 5 Credential 51

it took 5 or more hours to complete an application, with 1.2% (7 respondents) noting that the application took more than 16 hours to complete. Of those indicating that it took more than 16 hours to complete the application, three respondents were referring to the CDL, one was referring to the SIDA, one was referring to Department of Defense Security Clearance, one was referring to a training certificate, and one was refer- ring to a terminal-specific access credential. Respondents also reported their perceptions regarding the length of time it took for them to complete and submit their credential applications. As shown in Figure 3-14, most respon- dents (74.9%; 441 respondents) indicated that they believed the time needed to complete the application process was ade- quate. The remaining respondents thought that the application took too long (24.3%; 143 respondents) or way too long (6.3%; 37 respondents). Four respondents (0.7%) indicated that the process was too short. As stated, data linking respondent perception to reported time of application can be found in Appendix D. 28 15 38 0 5 10 15 20 25 30 35 40 45 50 M ar in e R es po ns e C ou nt 2 2 4 4 3 0 0 1 Credential 9 Figure 3-9. Credentials held by marine respondents. Figure 3-10. Credentials held by rail respondents. Figure 3-11. Summary of respondents’ total time needed to obtain credentials. Figure 3-12. Respondents’ perceptions regarding total time needed to obtain credential. Figure 3-13. Summary of respondents’ total time needed to complete the application process. 20 24 0 5 10 15 20 25 30 35 40 45 50 R ai l R es po ns e C ou nt 2 0 0 0 0 0 0 1 Credential 4 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% R es po ns e P er ce n t 17.6% 34.4% 29.5% 9.0% 3.7% 5.2% Less than 2 weeks 2 to 4 weeks 5 to 8 weeks Time 9 to 12 weeks 13 to 16 weeks Greater than 16 weeks 0.2% 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% Way T Sho R es po nd en t P er ce n t Perceptions 0.8% 39.7% 39.1% 20.2% oo rt Too Short About Right Too Long Way To Long o 63 0.0% 20.0% 40.0% 60.0% 80.0% 100.0% Les 2 h R es po n de n t P er c en t .2% 28.7% 6.0% 0.9% 1.2% s than ours 2 to 4 hours 5 to 8 hours 9 to 16 hours Greate than 1 hour Time r 6 s

Total Time to Pick Up Credentials Due to concerns regarding the distance that applicants must travel to complete the credential application process, respon- dents were asked to provide an estimate of the total travel time needed to obtain their credentials once the credential was ready (Figure 3-15). The majority of respondents (75.1%; 441 respondents) traveled less than 2 hours to obtain their cre- dentials. There were 92 respondents (15.7%) who traveled 2 to 4 hours, 33 respondents (5.6%) who traveled 5 to 8 hours, and 7 respondents (1.2%) who traveled 9 to 16 hours. Of the 2.4% (14 respondents) who indicated that they traveled more than 16 hours to obtain their credentials, they were referring to the following credential types: • CDL-HME (1 respondent); • TWIC (2 respondents); • FAST (2 respondents); • FUPAC (1 respondent); • Other (8 respondents), which includes – DOT physical long form and the DOT vision waiver (1 respondent), – Government clearance (1 respondent), – Passport (2 respondents), – State-specific railroad commission credential (1 respon- dent), – e-RAILSAFE system badge (1 respondent), – Criminal history check (1 respondent), and – Non-specified (1 respondent). Perceptions of the travel time required also were explored (Figure 3-16). The majority (64.4%; 378 respondents) indi- cated that the time needed to complete the application process was adequate. Less than 1% believed that the travel time was way too short or too short (0.5%, 3 respondents; and 0.3%; 2 respondents, respectively). The remaining 204 respondents (34.7%) indicated that they felt the travel time needed to pick up the credential took too long (26.7%; 157 respondents) or way too long (8.0%, 47 respondents). A full breakdown of per- ceptions corresponding with reported times are tabulated and graphically represented in Appendix D. Additional Respondent Feedback Respondents were provided an opportunity to express additional feedback regarding each credential they held. The CDL-HME feedback largely reflected redundancy concerns regarding the duplication of fees, security clearances, and fin- gerprinting. Respondents questioned the need for multiple credentials that relied on the same background check. Addi- tionally, there was an inconvenience associated with com- pleting the fingerprinting aspect of the application because applicants had to travel to get their fingerprints taken as 29 Figure 3-14. Respondents’ perceptions regarding time needed to complete the application process. Figure 3-15. Summary of respondents’ travel time needed to pick up credential. 0.2 0.0% 20.0% 40.0% 60.0% 80.0% 100.0% Way Too Short R es po nd en t P er ce n t Perceptions % 0.5% 74.9% 24.3% 6.3% Too Short About Right Too Long Way Too Long 75.1% 15.7% 5.6% 1.2% 2.4% 0.0% 20.0% 40.0% 60.0% 80.0% 100.0% Less than 2 hours 2 to 4 hours 5 to 8 hours 9 to 16 hours Greater than 16 hours R es po nd en t P er ce n t Time

opposed to having them taken at a local facility. Specific com- ments included the following: • “I pay a large fee to [state name redacted] for my CDL- HME, and then if I want to go into many of the ports I have to pay for a TWIC—which has the same background check—and then for a port issued credential as well—same background check.” • “Why so many background checks? Can’t these agencies talk to one another? Who gets the money? Why $83 for one check and $132 for TWIC and $25 for TSA? Why isn’t one background check enough?” • “You have to go to [a] special place to get fingerprints done rather than [a] local law enforcement office. Our place is about 1.5 hours away which is not very efficient.” • “Had to travel 4 hours to do fingerprinting.” Respondents were equally vocal when it came to provid- ing feedback for the TWIC. A large number of comments addressed the implementation and administration of this cre- dential. Respondents voiced concerns associated with TWIC office administration and locations, the design of the cards and included technologies, and general redundancies that they saw between the TWIC and CDL-HME. Specific concerns were categorized as administrative, implementation, redun- dancy, and improper education. Representative comments are as follows: • Administration Concerns – “TWIC offices were poorly administered. Too many losses of credential between offices.” – “Was told TWIC was in, went to get it twice and comput- ers were down.” – “Need more TWIC Centers throughout the state.” – “Why so expensive? The office had no parking for large trucks. Drivers had to take days off to get the TWIC.” • Implementation Concerns – “The readers should have been ready with the cards. As a ‘flash’ pass system it is a sham.” – “The physical cards are too fragile. Not all of the tech- nologies used in the card were properly tested and vetted. The failure rate of the actual cards is too high and there is a lack of understanding of the technologies used within the cards by the Trusted Agents involved in issuing the TWIC cards.” – “The idea is good; the implementation is sketchy at best and the card is not being utilized to its fullest.” • Redundancy Concerns – “Too expensive especially because I already have a CDL with HME.” – “TWIC is redundant having CDL-HME.” – “How many background checks do I need to have?” – “. . . Again, why so many checks? If the different agencies can’t talk to one another, what good is the system? $132 is a lot of money. This is another policy that only hurts the honest driver.” – “The TWIC card was easy to get however because I hold a Hazmat endorsement it is redundant in my mind. These two should work together.” • Concerns resulting from a lack of or improper education – “Gotta wonder why we are really doing this.” – “The applicant applying for the TWIC credential fails to understand the importance of providing proof of citizen- ship upon enrolling.” FAST respondents also voiced redundancy concerns. Again, a respondent expressed that s/he believed the credential to be a “waste of time and money.” Respondents also articulated administration-related comments, including: • “They lost it the first time.” • “There was some confusion about who I was because of someone with my same name that was a felon and it took a while to get the error corrected.” FAST respondents were also asked for their FAST creden- tial designations. The majority, 65.2% (15 respondents), held North designations, while 8.7% (2 respondents) held South 30 0.5% 0.3% 64.4% 26.7% 8.0% 0.0% 20.0% 40.0% 60.0% 80.0% 100.0% Way Too Short Too Short About Right Too Long Way Too Long R es po nd en t P er ce n t Perceptions Figure 3-16. Respondents’ perceptions regarding travel time needed to pick up the credential.

designations. Additionally, 26.1% (6 respondents) held both North and South designations (Figure 3-17). Three respondents who indicated they held a FUPAC pro- vided feedback. Again, concerns focused on the redundancies seen within the system. Comments regarding the FUPAC are as follows: • “Redundant gouging of my hard-earned dollars to do what my TWIC and CDL-HME already do. Clearly a cash cow for the port authority and nothing else.” • “[State name redacted] port’s background checks are unnec- essary, redundant, expensive, and time consuming.” • “Why did I have to get this thing[? I] already have a CDL [with] HME; for that matter why did I have to get the TWIC when I ALREADY HAVE A CDL [with] HME????? Does anyone realize what this is costing the drivers?” In regard to the MMC, respondents only provided clari- fication as to the process for obtaining the credential. Both comments indicated that no travel time was required to obtain the credential, which was delivered via mail to a home address. The same comment was made for the MMD. However, it also was noted that the MMD should not be required since the MMC is in place. The comment associ- ated with the SIDA simply indicated the agency affiliation of the respondent. When provided an opportunity to comment on additional credentials, redundancy was again the focus. Feedback pro- vided by respondents included the following: • “Testing required every 2 years, same test over and over.” • “It’s not about getting the credential as much as it is about duplicative efforts and one agency in the same department not [accepting] the information from another in the same department. Not just security issues either, i.e., physicals are a prime example—FAA, FMCSA, and USCG, to my knowl- edge, [none] of them [accept] this other at any level. [This causes] many in [state name redacted] heartburn.” Cost Analysis The cost data were primarily collected through the online application process of the issuing agency. Many of the creden- tials had a specific cost stated on the agency Web site. The cre- dentials, costs, and other associated data for 10 of the identified credentials are shown in Table 3-7. The costs associated with each credential were limited to the monetary requirement to obtain the credential. In some cases, additional costs existed for various purposes, including replacement fees or varied rates for qualifying applicants. For instance, the cost to acquire a TWIC can be reduced if the applicant already possesses several qualifying credentials that required a security threat assessment. Should an applicant exercise that option, the expiration date will be 5 years from the issue date of the qualifying credential, rather than 5 years from the issuance of the TWIC. The cost of the SIDA badges is vari- able, and according to the issuing airport. The USPS credential cost is determined by contract with the supplier company, not the individual. Because of these factors, cost data are difficult to report. As part of the cost data collection effort, the research team included the time period that the credential was valid. Most credentials are valid for 5 years. The passport and CDL both last 10 years before renewal is required (assuming the cre- dential-holder is 16 years or older for the passport). However, the HME portion of the CDL-HME must be renewed every 5 years, regardless of CDL renewal. Since each state (and the District of Columbia) issues a separate CDL-HME credential, the research team placed the cost data in a separate cost table. Table E-1 (see Appen- dix E) includes both the costs of a new CDL credential with an HME endorsement as well as the costs for the threat assessment application for each state (and the District of Columbia). The credential fees for a CDL-HME (includ- ing threat assessment fees) ranged from a low of $107.25 (North Dakota) to a high of $326.25 (New York). Figure 3-18 provides the CDL count by cost range (excluding the cost for a threat assessment) for all 50 states and the District of Columbia. 31 Figure 3-17. FAST credential designations. South, 8.7% Both, 26.1% North, 65.2% Credential Stated Costs Valid for (Years) SIDA $91.33* 2 Passport $100.00 10 TWIC $132.50 5 MMD $100.00 5 MMC $100.00 5 FAST $50.00 5 USPS Unavailable 4 NEXUS $50.00 5 SENTRI $122.25 5 CAC Unavailable 3 *SIDA costs are an arithmetic mean, see Appendix F. Table 3-7. Credential costs.

Although the majority of states charge between $25 and $50 for the CDL and HazMat endorsement, there is some amount of variation throughout the country. This appears to be due to variation in how each state structures its fees for licensing. In some cases the fee is mandated by state statute and thus a change to the fee requires legislative action. An increase in this fee may be politically untenable for state politicians. In other states the fee structure is required to reflect the cost to the state, and as such must continuously increase as the cost to the state increases. Federally mandated security threat assessment fees are shown in Figure 3-19. When compared to the cost for the CDL, the variation is cer- tainly less. This is most likely due to the fee structure originally set at the federal level. The few instances that vary are likely due to states that opted out of having the TSA collect the required data, and potentially are the result of additional processing at the issuing agency’s prerogative. Nine of the eleven identified credentials under consideration required fingerprinting to acquire. Thus, at least some of the costs associated with each credential cover the fingerprinting fee. Additionally, the requirements for criminal history record checks, criminal background checks, or security threat assess- ments for each of the credentials contribute to the total cost of the credential. Use Cases To better understand the user costs of credentialing, an additional cost analysis was conducted with self-reported costs of specific HazMat transportation workers. The use cases are drawn from the Web-based survey and telephone interviews with credential-holders. The use cases served two purposes. First, they identified the most commonly held combinations of credentials as identified by Web survey respondents and asso- ciated costs. Second, through interviews with current CMV drivers, out-of-pocket costs and time-to-obtain costs were explored. Commonly held credentials were identified based upon a review of the HazMat Security Credential Survey responses. Survey respondents were asked if they currently held the fol- lowing credentials: CDL-HME, TWIC, FAST, FUPAC, MMC, MMD, MML, NEXUS, SENTRI, SIDA, and other. Respon- dents’ answers revealed 55 combinations of credentials. Due to the “other” option, 43 of the identified combinations were associated with only one respondent each. Looking at the 12 most common credentials, with input from the 43 other com- binations, 5 combinations of credentials were chosen for fur- ther analysis. The combinations were chosen because they reflect the most commonly held credential combinations as well as combinations that would provide a multimodal perspective. Applying cost data to the most commonly held credentials provides a snapshot of the costs incurred by survey respon- dents (Table 3-8). The combined costs range from $232.50 to $434.72. Five individuals were identified for follow-up interviews. The five individuals represented the highway/tractor-trailer mode and were CMV drivers. Four individuals were male and one was female. Mean years of experience was 20.7 years, with the median years of experience being 21.5 years. The mean age of responders was 56 and the median age was 58. The mean salary was approximately $53,000, which converts to an aver- age hourly wage of $25.50. Four of the individuals spoken to held CDL-HME, TWIC, and U.S. passport credentials. One individual held a CDL-HME, a TWIC, and a credential issued by a local authority. All interviewees held CDL-HMEs. The time it took them to obtain the CDL-HME ranged from 1 hour to 3 or 4 months. Four responded that it took 20 to 30 minutes to complete the application. One responded that it took all day, but that included the testing portion of the application as well. On average, the CDL-HME cost $100, for which only one received reimbursement. Although the application process was reported to be quick and fairly simple (especially if all data were gath- ered prior to completing the form), the cost and time associated with fingerprinting were noted. For example, one respondent has had his fingerprints taken four times, which required a 300-mile round trip each time. 32 Figure 3-18. Counts by CDL Cost Range. Figure 3-19. Counts by threat assessment cost range. 2 24 11 8 3 2 0 1 0 5 10 15 20 25 30 C ou n t Cost 1 2 42 3 0 1 1 0 1 0 5 10 15 20 25 30 35 40 45 Co un t Cost

All interviewees also held TWIC cards. The total time to obtain the TWIC ranged from 2 to 6 weeks and, on average, individuals spent 30 minutes completing the application. Three of the respondents indicated that they traveled 15 to 20 minutes to pick up their TWIC cards; however, one individ- ual reported a shorter time and one noted that it was a 2-hour trip each way. On average, individuals paid $168 for the TWIC, a cost which all reported as being reimbursed. Additionally, individuals noted concern with the cost of renewing a creden- tial, the duration of validity for a credential (especially for drivers with clean driving records), and that individuals should not wait until the last minute to apply. Four of the interviewees noted that they held U.S. passports. On average, it took 3 weeks for the passport to arrive with the application completion time being, on average, 30 minutes. Only one individual traveled to pick up the passport while the others had the passports mailed to their homes. The average cost of the passport was $101.25 and all indicated that they were reimbursed this cost. One individual held a credential that was issued by a local authority (in this case, a police department). The credential required an application, a background check, and a $200 fee, which the company did not reimburse. The total time to obtain the credential was 2 to 3 days. The time to complete the appli- cation was negligible (i.e., “quick”) and required 15 miles travel to the police station to pick up the credential. Comments regarding this credential were similar to the comments made regarding this same credential in the Web-based survey. The purpose of this credential is perceived as being a revenue tool for the local authority versus a means of ensuring safety or security. Based on the information above, the shortest amount of time it took to complete an application was 15 minutes and the longest it took to complete the application was 1 day. Using an hourly wage of $25.50 (assuming a working year of 2,080 hours), the shortest amount of lost work time due to completing the application converts to a loss of $6.38 in pay, while the longest amount of lost work time due to completing the application equals a loss of $255.50 in pay. However, none of the individuals indicated that they lost a day’s work to obtain the credential. All noted that they obtained their credentials on personal time. Assuming the minimum credential, application, and travel costs incurred by the individuals interviewed and their com- panies, the minimum average cost ranges from $375.63 (CDL- HME, TWIC, U.S. passport) to $468.00 (CDL-HME, TWIC, local authority credential). Conversely, assuming the maxi- mum credential, application, and travel costs incurred by the individuals interviewed and their companies, the maximum average cost ranges from $726.75 (CDL-HME, TWIC, U.S. passport) to $825.50 (CDL-HME, TWIC, local authority credential). Regulatory Analysis The events of September 11, 2001, brought about renewed concerns regarding security and safety in the transport of haz- ardous materials across all modes. In response, Homeland Security Presidential Directive 12 (HSPD 12), dated August 27, 2004, “Policy for a Common Identification Standard for Fed- eral Employees and Contractors,” was implemented. HSPD 12 called for a single federal employee ID card. For all transporta- tion modes, the principal policy objectives that supported the issuance of HazMat credentials were • To ensure the trustworthiness of the passengers and the cargo flowing through the system; • To ensure the trustworthiness of the transportation workers who operate and service the vehicles, assist the passengers, or handle the cargo; • To ensure the trustworthiness of the private companies that operate in the system, such as the carriers, shippers, agents, and brokers; and, • To establish a perimeter of security around transportation facilities and vehicles in operation. Additionally, the USA PATRIOT Act of 2001 (Pub. L. 107-56) strengthened security for homeland defense against terrorism purposes. Of interest to this analysis is Section 1012 of Pub. L. 107-56, which places increased limitations on the 33 Table 3-8. Cost information for the five most common credential combinations. Credential Combination Individual Credential Costs Total Credential Combination Costs 22.251$CIWTdnaEMH-LDC a + $132.50 $284.72 CDL-HME, TWIC, and FAST $152.22a + $132.50 + $50 $334.72 CDL-HME, TWIC, FAST, and U.S. Passport $152.22a + $132.50 + $50 + $100 $434.72 CDL-HME, TWIC, and SIDA $152.22a + $132.50 + $91.33b $376.05 05.232$00.001$+05.231$CMMdnaCIWT Notes: aRepresents the mean combined CDL-HME stated cost ($61.96) and threat assessment fee ($90.26). bRepresents an average of identified SIDA fees (see Appendix F.)

issuance of HazMat licenses. Section 1012 amends Chapter 51 of Title 49, U.S.C., by inserting a new section after Section 5103 (i.e., Section 5103a, Limitation on Issuance of HazMat Licenses). Under Section 5103a, states may not issue or renew a license to operate a motor vehicle transporting hazardous materials in commerce unless the Secretary of Transportation has first determined through the receipt of a notification of results of a background check that the individual does not pose a security risk warranting denial of the license. The background check required under Section 5103a(c) is to be carried out by the Attorney General at the request of the state. The Attorney General is to complete a background check to include • A check of the relevant criminal history databases; • In the case of a foreign national, a check of the relevant databases to determine the status of the foreign national under the immigration laws of the United States; and • As appropriate, a check of the relevant international data- bases through INTERPOL-U.S. National Central Bureau or other appropriate means. As part of this analysis effort, upper-level security personnel in a number of the nation’s ports were contacted. The purpose of this contact was to obtain expert insight into the acceptance of the TWIC as an authoritative security credential. Determin- ing the acceptance of, and reliance upon, the TWIC by major ports was necessary because the regulations currently allow plant or facility owners to issue facility-specific identification cards as their access control measure, as long as it is ensured that individuals without a TWIC cannot gain unescorted access to secure areas and if the TWIC is checked at least once before the specific card is reissued or accepted. Of the 75 ports contacted, 35 continued to issue and require facility-specific security credentials. Forty of the ports contacted reported using only the TWIC as the authorized security access credential. Sev- eral ports that required only the TWIC noted that the require- ment of an additional facility-specific identification would result in the duplication of federal security efforts. Appendix G contains the specific ports contacted and their corresponding responses. Authorities, Policies, Programs, and Exemptions by Credential To determine the feasibility of a consolidated security cre- dential, one must consider the purpose each individual creden- tial is intended to serve and its unique characteristics. Table 3-9 will provide an overview of the following features of each credential: • Authority: Provides the authority under which the over- sight agency created the security credential. The sources of authority discussed are – Congressional authority—The impetus for particular policies and/or the oversight organization itself is the result of legislative action; – Executive authority—Indicates the impetus originated with an executive order, executive directive, or agential rulemaking; and – Local authority—Refers to those policies established by state, local, or regional special authority (for example, the establishment of a port authority and subsequent port operating procedures). • Policy: Outlines the desired outcome or effect of the action as well as guidelines that govern how laws or regulations should be put into operation. • Program: Discusses the parties and organizations respon- sible for implementation of the policy and any specific requirements or modifications required for implementa- tion, oversight, and governance. • Exemptions: Presents any identified qualifiers to the afore- mentioned policies. SWOT Analysis Consolidated Credential Approach The research team analyzed the feasibility of a consolidated credential using a SWOT analysis. The SWOT analysis for this project consisted of determining a proposed consolidation process, which was subsequently analyzed from two perspec- tives: security and cost-effectiveness. Prior to analyzing the consolidation process, an explanation of the developed credentialing model will be provided, includ- ing the assumptions taken during analysis. For review of the identified credentials from Task 1, the research team identified not only the security credentials required of persons who trans- port hazardous materials but also the safety credentials that are related to the competency (or skill) of the person. The reason- ing for this expanded analysis was twofold: (1) several creden- tials contained a mixture of security and safety components, and (2) it provided a complete depiction of the credentialing process. Again, two of the identified credentials (CDL-HME and MMC) do not fit entirely into either security or safety, but overlap both categories. The CDL is a safety credential. To receive the HME endorsement one must demonstrate knowl- edge of HazMat shipping and regulatory procedures and undergo a security threat assessment per the USA PATRIOT Act. The MMC is a consolidation of the MMD, MML, and STCW. In each case, these credentials exhibit a dual intent and are, therefore, represented on a separate plane of the model indicating their uniqueness within the identified credentials (Figure 3-2). Security involves two aspects: (1) the vetting process of the potential credential-holder, and (2) the capability to effectively 34

35 Table 3-9. Overview of credential by characteristic. Transportation Worker Identification Credential (TWIC) (29) Authority • Congressional Policy • Maritime Transportation Security Act of 2002, Public Law 107-295, Nov. 25, 2002, and 46 U.S.C. 70195 • The TWIC is used for visual identity checks. • It is anticipated that more than 1 million workers (30), including longshoremen, truckers, port employees, vessel crews, outer continental shelf facility workers, and all credentialed merchant mariners, will ultimately be covered by the TWIC. Program • TSA is required to issue a biometric, tamper-resistant security credential to individuals seeking unescorted access to port areas. • Initially it was intended to cover approximately 3,500 facilities, 10,800 vessels, and all USCG-credentialed merchant mariners.(31) Exemption • A TWIC applicant who has already secured an HME security threat assessment is not required to repeat the threat assessment in order to obtain the TWIC. • A non-TWIC holder may be escorted by a TWIC holder if the TWIC holder has met the security training requirements and has knowledge of escorting procedures and contingency plans if an escorted individual is engaged in another purpose aside from that for which they were granted access. Commercial Driver’s License—Hazardous Materials Endorsement (CDL-HME) (32) Authority • Congressional • Executive Policy • The Commercial Motor Vehicle Safety Act of 1986, 49 USC 5103a, and 49 CFR 1572. • The CMVSA established minimum nationwide standards that must be met when a CDL is issued. Commercial drivers who carry hazardous materials must acquire a Class A, B, or C license and obtain an HME endorsement, which includes a HazMat knowledge test and a TSA HazMat Driver Threat Assessment, or an X endorsement, which is a combination of tank vehicle and HME endorsements. • 49 CFR 1572.9, the TSA HazMat Driver Threat Assessment Program, requires threat assessments for all individuals who apply for, renew, or transfer an HME onto their CDL. Program • States are to determine the application process, license fee, license renewal cycle, renewal procedures, and reinstatement requirements after a disqualification event. These processes and requirements must meet federal standards and criteria; however, states may exceed the federal requirements for certain criteria, such as medical, fitness, and other driver qualifications. • States must connect to the Commercial Driver's License Information System and the National Driver Register in order to exchange information about CDL drivers, traffic convictions, disqualifications, a driver's record, and to make certain that the applicant does not already have a CDL. • Applicants are required to pass a written test (consisting of 30 questions) pertaining to the over-the-road transport of hazardous materials, must comply with the standards specified in TSA requirements, and provide proof of citizenship or immigration status. Exemption • Each state must exempt individuals who operate CMVs for military purposes. • A state may, at its discretion, exempt firefighters, emergency response vehicle drivers, farmers, and drivers removing snow and ice in small communities • A state may issue a restricted license and waive the CDL knowledge and skills testing requirements for seasonal drivers in farm-related service industries and may waive certain knowledge and skills testing requirements for drivers in remote areas of Alaska. • A state also can waive the CDL-HME test requirements for part-time drivers working for the pyrotechnics industry. (continued on next page)

36 Policy • 33 CFR 101-106, 46 CFR Parts 10-16. • The MMD seeks to increase safety standards in the maritime industry with the goal of encouraging ongoing training and knowledge of advancements in the field, which is accomplished through the renewal process. Program • The U.S. Coast Guard’s National Maritime Center oversees the issuance of the MMD. • The MMD was one of the standard documents required for all crewmembers of U.S. ships with a gross register tonnage (GRT) of more than 100 tons. • An entry-level MMD allowed a mariner to work on the deck as an Ordinary Seaman, in the Engine Department as a wiper, or in the Steward's Department as a food handler. With experience and testing, qualified ratings such as able seaman (AB) or qualified member of the Engine Department can be obtained. • All applicants for an MMD are required to take a drug test and undergo a criminal background check before receiving their documents, which may take anywhere from a few weeks to 6 months. Exemption • The MMD is being incorporated into the MMC. Mariners will receive the new credential when they apply for a new document or renew their current document. Current MMDs remain valid until their expiration date. Merchant Mariner Credential (MMC) (34) Authority • Executive Policy • 46 CFR Part 10 complies with the International Convention of the STCW, which was adopted by the International Maritime Organization in 1978 and amended in 1995. • The MMC is intended to be a single credential incorporating the MML, Certificate of Registry, STCW, and MMD as of April 15, 2009. • Much like the MMD, the MMC ensures ongoing training and knowledge of advancements in the field. Program • The U.S. Coast Guard’s National Maritime Center oversees the issuance of the MMC. • The MMC has two categories, Domestic and International Endorsements. • The 14 international, or STCW, endorsements coincide with the current STCW Certificate. Exemption • A Document of Continuity will take the place of renewing a credential. This single document will incorporate all of the capacities that are being placed in continuity status and will have no expiration date. Security Identification Display Area (SIDA) (35) Merchant Mariner Document (MMD) (33) Authority • Executive Authority • Executive Policy • 49 CFR 1542, 1544. • The SIDA credential provides visual identification of persons in the secure areas. Program • The SIDA badge is issued by the local airport after it forwards the required information to the American Association of Airport Executives (AAAE), which then forwards the information to the FBI and TSA. • The SIDA badge is used to monitor individuals who need to have unescorted access to secure areas of airports and aircrafts. In some cases the SIDA badge may identify Table 3-9. (Continued).

37 Free and Secure Trade (FAST) (36) Authority • Congressional Policy • Public Law 109-59 (i.e., SAFETEA-LU); Canada’s Partners in Protection Program; and the U.S. Customs-Trade Partnership Against Terrorism Program. • FAST, as part of the Trusted Traveler Program, seeks to enhance border and trade chain security while making cross-border commercial shipments simpler and subject to fewer delays. Program • FAST is overseen by U.S. Customs and Border Protection. • FAST expedites the border clearance process for low-risk, pre-approved travelers between Canada and the United States, and between Mexico and the United States. FAST decal holders have access to specially marked lanes at border crossings, thus enabling the holder to avoid back-ups at regular crossing lanes. NEXUS (37) Authority • Congressional Policy • Public Law 109-59 (i.e., SAFETEA-LU); Canada’s Partners in Protection Program; and the U.S. Customs-Trade Partnership Against Terrorism Program. • NEXUS, as part of the Trusted Traveler Program, seeks to enhance border and trade chain security while making cross-border commercial shipments simpler and subject to fewer delays. Program • NEXUS is overseen by U.S. Customs and Border Protection and expedites the border clearance process for low-risk, pre-approved travelers into Canada and the United States for all modes of transportation. specific areas that the SIDA badge-holder may enter. For example, at Washington Dulles International Airport (IAD), the badge is color-coded to signify the level of access. • To obtain a SIDA badge, the individual must have a TSA threat assessment, proof of citizenship or immigration status, criminal history check, fingerprints, and personal identification information. • The NEXUS card uses iris recognition biometric technology for persons who arrive in the United States by air. Commercial drivers use a specially marked lane and show their NEXUS membership card in front of a proximity card reader; a visual inspection follows. If arriving by sea, all persons onboard a boat must be NEXUS members in order to take advantage of NEXUS reporting procedures. • Customs is provided with an estimated time of arrival, landing information, origin and destination information, registration information, crew information, and a declaration of all goods being imported, including related currency information. Secure Electronic Network for Travelers Rapid Inspection (SENTRI) (38) Authority • Congressional Policy • Public Law 109-59 (i.e., SAFETEA-LU). • SENTRI, as part of the Trusted Traveler Program, seeks to enhance border and trade chain security while making cross-border commercial shipments simpler and subject to fewer delays. Program • SENTRI is overseen by U.S. Customs and Border Protection and expedites crossing over the Southwest Land Border (Mexico/United States). The SENTRI card provides expedited processing for pre-approved, low-risk travelers. • Applicants must voluntarily undergo a thorough biographical background check against criminal, law enforcement, customs, immigration, and terrorist databases; a fingerprint-based criminal history check law enforcement check; and a personal interview with a CBP officer. Once approved, applicants are issued identification cards and vehicle decals. Table 3-9. (Continued). (continued on next page)

38 character, and loyal to the United States. Specifically, applicants’ current employers are contacted to inquire as to the applicants’ adherence to security requirements; honesty and integrity; vulnerability to exploitation or coercion; falsification, misrepresentation, and any other behavior, activities, or associations that tend to show the person is not reliable, trustworthy, or loyal. Passport (40) Authority • Congressional • Executive Policy • 8 USC 1185[b] and 22 CFR 53. • On June 1, 2009, the final phase of the Western Hemisphere Travel Initiative (WHTI) (41) went into effect for land and sea travel into the United States (requirements for air travel went into effect in 2007). The WHTI is a result of the Intelligence Reform and Terrorism Prevention Act of 2004. • The goal of the WHTI is to facilitate entry for U.S. citizens and legitimate foreign visitors while strengthening U.S. border security. Program • Department of State issues passports for the purpose of documenting the identity and nationality of passport holders. The elements of identity are name, date of birth, sex, and place of birth. Most often, nationality and citizenship are congruent. • It is unlawful for any citizen to depart from or enter, or attempt to depart from or enter, the United States without a valid passport. Passports are used to ensure that DHS is able to quickly and reliably identify travelers. U.S. Department of Defense Common Access Card (CAC) (42) Authority • Executive Policy • Homeland Security Presidential Directive 12 (HSPD-12). • As of 2008, the Department of Defense had issued more than 17 million cards. Program • The Department of Defense began issuing its CAC in October 2006 as a standard ID card that has extensive data storage on an embedded integrated circuit chip that permits rapid authentication and enhanced security for all physical and logical access. • All personnel enrolled in the Defense Enrollment Eligibility Reporting System (DEERS) database are eligible for the card. • Applicants undergo an FBI fingerprint check and a National Agency Check with Inquiries (NACI) background security check. United States Postal Service (USPS) (39) Authority • Congressional • Executive Policy • USC 3301-3302; 5 CFR 5, 731, 732, 736; and Executive Orders 10450 and 105775. • USPS screening is used to determine USPS employees’ eligibility to transport mail and to gain access to mail and mail processing facilities. Program • USPS oversees this program and ensures that mail delivery personnel and contractors must also ensure that all persons who require access to mail facilities or drivers are screened. • Individuals are screened every 4 years and are provided with either a non-sensitive or sensitive clearance. Applicants for the non-sensitive clearances must submit to background investigations, fingerprinting, review of a current driving record, and must provide passport-sized pictures. • Sensitive (i.e., public trust) clearances require individuals to complete a separate questionnaire in addition to meeting the requirements of the non-sensitive process. The background investigations are conducted based on questionnaire responses that indicate whether an applicant is reliable, trustworthy, of good conduct and Table 3-9. (Continued).

communicate the identification and authentication informa- tion of the credential-holder. Therefore, the results of the secu- rity SWOT will be classified as either vetting (assessing the threat/risk of the person) or communicating (conveying iden- tification and authentication). For the purpose of assessing the feasibility of consolidating credentials, the following assump- tions were made by the research team to frame the SWOT analysis: • Assumptions with similarities to current processes – The existing issuing agencies would continue to issue the consolidated credential and – The processes utilized by the issuing agencies to collect and assess applicant data would remain relatively similar. • Assumptions with differences to current processes – The application process would require a standardized application collecting the same data from each applicant regardless of mode, – Each applicant would be vetted to the same level, requir- ing a full threat assessment (background check, criminal history check, etc.) for each applicant, – Each issuing agency would issue the same standardized security credential applicable to all modes and would provide a credential-holder with the ability to access mul- tiple facilities without additional security credentials, and – Tiered access to secure areas would be granted using administrative and technical controls established by those individual facilities. Consolidated Credential—Security SWOT Credentials with a security focus place emphasis on iden- tifying the credential-holder and ensuring appropriate entry to access-controlled areas. As mentioned, the results of the security SWOT will be classified as either vetting (assessing the threat/risk of the person) or communicating (conveying identification and authentication), as seen in Table 3-10. The strengths and weaknesses of the SWOT analysis refer to the internal benefits and disadvantages of a process. For the consolidation of the security credentials, strengths and weak- nesses refer to the assessment (or vetting) of an applicant’s security threat/risk. Conversely, the opportunities and threats refer to the credential’s communication of the identity of the credential-holder. Strengths. A consolidated security credential with a unique serial number used across all modes and by all personnel related to the transportation of hazardous materials would provide an efficient method for tracking credential-holders. This would be beneficial to issuing authorities for the purposes of notification of credential modifications due to policy changes. Further- more, security is enhanced because credential data could be tracked across facilities and quickly accessed across multiple databases. Currently, facility credentials have multiple disqualifying offenses, or threats, that they must mitigate. Consolidation of the security credentials would merge many of the threats, cre- ating a minimum threshold to which all applicants would be held accountable. This would create a minimum standard regarding the character of individuals holding this credential. The consolidation process would require the current assorted procedures for the applicants’ risk assessments to be combined, eliminating the need for multiple searches among relevant databases to determine the threat of a single applicant. This would eliminate numerous redundancies for the various agen- cies while ensuring that the highest level of security is main- tained through a minimum-security threshold equal to the most secure individual credential currently in use. 39 V et tin g (In ter n a l) Strengths • Better tracking of applicants • Simplifies “threats to mitigate” list • Ensures a minimum threshold for security • Quickly adapts policy for new threats Weaknesses • Institutional resistance • State and federal legislative actions required • International issues • Decreased resolution regarding the “threats to mitigate” list C o m m u n ic a tin g (E xte rn a l) Opportunities • One credential for end-user • Uniform look and design on the credential • Simplifies training for security personnel • Only one issuing agency to notify if problems arise Threats • Increased ability to abuse/misuse Table 3-10. SWOT analysis results from a security perspective.

There also would be an added benefit related to policy adap- tation. When necessary, a single credential falling under a sin- gle policy could be adjusted quickly to adapt to new threats. This would create a much more efficient system, enabling all modes and all facilities to quickly react to the most current security threats. Additionally, by having a single credentialing system, a credential-holder would need to report the loss of a credential only once to facilitate the notification across all modes and all facilities of a potential security breach. This sin- gle point of contact would drastically improve the speed with which the entire system counters a potential threat. Weaknesses. The primary weakness of a consolidated approach would be the implementation issues typically asso- ciated with the establishment of a new process. A single creden- tial would be applicable to many facilities under the control of multiple agencies. Therefore, the consolidated security creden- tial would require effective communication and cooperation across multiple agencies to address administrative and policy issues and ensure successful implementation. For those security credentials designed for border crossings (i.e., passport, FAST, NEXUS, SENTRI), there are disadvan- tages with attempting to consolidate with domestic security credentials. Those credentials that are intended to be used at border crossings have a different focus than the remaining security credentials. This subdivision among the security cre- dentials creates complexity from a consolidation perspective. For example, the disqualifying offenses for the passport are focused on very different threats as compared to the disqual- ifying offenses for the facility security credentials. The consolidation of the disqualifying offenses, or threats to mitigate list, may result in a loss of function-specific focus. Each current credential is designed with a given intent and specific threats. Opportunities. The most obvious opportunity is the gen- eration of a single security credential that would allow the end- user to access controlled areas of multiple facilities (e.g., marine ports, airports, and rail yards) without the need to apply for, and acquire, a new credential at each facility. The credential- holder would only need to maintain one security card, which will result in numerous economic advantages that will be discussed in the cost-effectiveness SWOT analysis. A single credential would possess a uniform design and look. From a human factors perspective, a standardized look facili- tates universal recognition across participating facilities. This increases awareness and propensity for security challenges to the credential-holder. A positive result of this uniform look is the simplification of training for security personnel. In all modes, and at all facilities, the security personnel will evaluate the same credential. A consolidated credential would streamline the process for notifying an issuing agency of problems (e.g., loss, theft) of the security credential. With the current credentialing process, the credential-holder must contact numerous issuing agen- cies if problems arise. With only one security credential, the credential-holder would need to only contact one agency to resolve any problems that occur. Threats. As previously stated, a single facility security cre- dential would provide access for applicable personnel to mul- tiple facilities, thereby easing the process for those personnel; however, this is also a threat in that it would create a “single key” scenario. That is, someone who possesses a valid consoli- dated security credential could potentially access other facili- ties for illegitimate purposes. Also, should the credential be compromised (i.e., counterfeited) it could be used to access more facilities than any currently existing credential. Creden- tial abuse or misuse is certainly a threat; however, there is the potential to combat this issue using administrative controls on a need-to-access basis. Based on the results of the SWOT analysis from a security perspective, the research team concluded that the intent of several security credentials (i.e., U.S. passport, FAST, NEXUS, and SENTRI) is too varied to be considered equal to the remaining security credentials. These four security credentials are focused on the identification of the credential-holder at border crossings; the remaining credentials are focused on identification and facility access. Therefore, the original model was revised to reflect this additional (third) category, as shown in Figure 3-20. Consolidated Credential—Cost-Effectiveness SWOT The final SWOT analysis for a consolidated credential focused on cost-effectiveness for a consolidated security cre- dential and a consolidated safety credential. The evaluation focused primarily on the increased or decreased costs associ- ated with a consolidated credential for both the issuing agen- cies (strengths/weaknesses) and potential credential-holders (opportunities/threats). The results are included in Table 3-11. 40 Figure 3-20. Revised model of categorized credentials.

Strengths. The primary strength of a consolidated creden- tial is the elimination of cost redundancies. Currently, each credential application must be handled and processed as if it represents a unique individual. For example, an individual applying for two credentials would be required to complete two separate applications, including two security threat assessments. Reducing the number of applications will directly result in a decrease in time and effort required by the issuing agencies. A single credential with a uniform look and design could facilitate a faster and more simplified training program for secu- rity and inspection personnel. Weaknesses. Because additional technology will be required (as was needed for the TWIC) across all modes to fully utilize the consolidated credential, there will be an increase in cost to the individual facilities. This cost is potentially signifi- cant if the technology required is not currently in use and must be acquired by all facilities for all transportation modes. An example would be a card reader that must be installed at each gate of all ports, airports, and other secure facilities, in police cars, weigh stations, and any other inspection facility. Opportunities. The most apparent and potentially sig- nificant opportunity for consolidation is the elimination of redundancies from the perspective of a credential-holder. The elimination of multiple applications and the associated fees, the reduction in time requirements associated with filling out and submitting multiple applications, and the elimination of numerous trips to facilities (for application, fingerprinting, and receiving the credential) will result in significant cost sav- ings for credential-holders. In addition, most existing creden- tialing centers could be available to all applicants regardless of transportation mode, decreasing travel times, and increasing availability of resources. Threats. The consolidated credential approach presented no specific cost-related issues for the credential user. Non-Consolidated Credential Approach The research team used a SWOT analysis to evaluate the non-consolidated credential option (the current system) to allow for comparisons. In the same manner, the SWOT analy- sis for the non-consolidated credential approach was con- ducted from both a security and cost-effectiveness perspective. Non-Consolidated Credential—Security SWOT The results of the security SWOT will be classified as either vetting (assessing the threat/risk of the person) or communi- cating (conveying identification and authentication) as seen in Table 3-12. Strengths. As seen in the requirements-to-obtain and dis- qualifying offenses sections, each issuing agency assesses the threats specific to its concerns for each of its applicants and can afford to do this due to the limited information required. By focusing its assessment and limiting the information to what is necessary for its purposes, the issuing agency can assess each applicant with greater resolution, which results in enhanced security. Weaknesses. With multiple credentials and correspon- ding issuing agencies, the threat increases that a credential- holder is deemed an unacceptable risk by one agency and the information will either be delayed or never reach other agencies (or facilities) due to the complexities of sharing such information across multiple data platforms and agency facilities. Opportunities. The amount of information placed on each credential varies based on the issuing agency, the type, and purpose of each. Where a consolidated credential would need to contain the information necessary for all purposes, non- consolidated credentials can be specifically tailored for their purposes. This design allows for immediate recognition for 41 V et tin g (In ter n a l) Strengths • Eliminates redundancies for issuing agency • Decreases training requirements for security personnel Weaknesses • Requires new or additional technology C o m m u n ic at io n (E xte rn a l) Opportunities • Eliminates redundancies for credential user • Increases availability of enrollment centers(43) Threats • None identified Table 3-11. SWOT analysis results from a cost-effectiveness perspective.

security personnel, as well as for fellow employees within a challenge program. Threats. Inherent in a credentialing system with multiple credentials issued by multiple agencies is variance in the appearance of the credentials. When referring to multiple modes of transport and multiple facilities, the variance of these security credentials can increase the risk of fraudulent credentials being successfully used to gain access to a secure facility. Although technology exists to combat this threat, a non-consolidated system allows each issuing agency to decide what type of credential should be developed. Non-Consolidated Credential— Cost-Effectiveness SWOT The non-consolidated credential approach evaluates the cost-effectiveness from both an issuing agency perspec- tive (strengths and weaknesses) and the perspective of the credential-holder (opportunities and threats). The SWOT results are provided in Table 3-13. Strengths. From a cost-effectiveness standpoint, no spe- cific strength for the issuing agency was identified. Weaknesses. For each applicant there is an associated cost to process the application and any related threat assessments. For the non-consolidated credential approach, the same appli- cant will need to apply multiple times to gain access to certain facilities. Although some portion of each application may be unique, the security threat assessment portion will not be dis- tinctive. Each additional search for an applicant raises the cost of administration, adds to the list of applicants to assess, and potentially delays the process. Opportunities. No specific opportunities for improved cost-effectiveness for credential users were identified. Threats. Similar to the additional administrative costs for each agency related to the need for multiple credentials, the costs to the potential credential-holder are also increased. These additional costs will result from multiple applications, fingerprinting, trips to an issuing agency, and time required to fill out applications. Because of the multiple designs and features of the individ- ual credentials, to ensure security, facilities will need to provide specialized training (at additional time and cost) for the recog- nition and monitoring of these unique details. 42 Table 3-13. SWOT analysis results from a cost- effectiveness perspective (non-consolidated approach). V et tin g (In ter n a l) Strengths • None identified Weaknesses • Increased administrative costs • Multiple enrollment centers and forms C o m m u n ic a tio n (E xte rn a l) Opportunities • None identified Threats • Multiple credential costs • Multiple enrollment centers and various forms • More training for facility security personnel Table 3-12. SWOT analysis results from a security perspective (non-consolidated approach). V et tin g (In ter n a l) Strengths • Focused applicant assessment Weaknesses • Complexity of information sharing • Inconsistent vetting processes(30) • Re-vetting of the same people(30) • Inefficient information and data collection(30) • Data collection or processing errors(43) C o m m u n ic at io n (E xte rn a l) Opportunities • Tailored credentialing Threats • Variance in credential appearance

Consolidation Options Analysis Each of the existing security credentials within the current transportation system has a unique purpose and has been developed with that specific purpose in mind. The combina- tion of credentials requires that the consolidation still functions for its intended purpose. Therefore, the research team broke down each current credential (and acquisition/application process) into the very elements constituting the credentials (see Table 3-2, Table 3-4, Table C-1, Table C-2, and Table C-3). This allowed for an evaluation of basic credential “building blocks.” The research team then combined candidate cre- dentials in various options (shown in Table 3-14), which resulted in new combinations of elements. The options were developed through dialogue with the TAG, results of the online survey instrument, and as a result of the Phase I analysis. Option 1 consisted solely of the TWIC due to suggestions that the TWIC should be considered as a stand- alone solution for consolidating security credentials for trans- portation workers. The results of the Phase 1 analysis showed the TWIC to be potentially limited as to its applicability in all modes. Potential limitations were due to the assumption that each credential’s identified elements are necessary for it to func- tion as a security credential. When a comparison was made, it was determined that the TWIC had very few elements in com- mon with other credentials. The results of this comparison were presented accordingly in the elemental matrices. Option 2 (TWIC, MMD, SIDA, USPS, CAC) was simply the combina- tion of all credentials that appeared to show promise for suc- cessful consolidation based on the Phase I analysis. This combination of all credentials deemed feasible for consolida- tion provided the upper bounding of required elements and functionality. Therefore, Option 2 captured each unique ele- ment and the associated background checks necessary for a consolidated credential replacing five credentials, and covering all four transportation modes. Option 3 (TWIC, MMD) was chosen to evaluate the consolidation of two credentials cur- rently being used within the marine mode. An evaluation of this combination of credentials could determine if there is more potential for success within a given mode, or regardless of mode. Option 4 (TWIC, SIDA, CAC, MMD) comprised all of the elements of Option 2 except the USPS credential. The results of the research indicated that the USPS was held quite infrequently, and does not have a significant role in HazMat transportation. Therefore, Option 4 was designed to evaluate the impact of this credential on the overall consolidation process. It is important to note that the CDL-HME as a whole is a vastly different type of credential; however, for purposes of inquiry and comparison, the security portion of the HME could be viewed as equivalent to the TWIC because of the many similarities between the two credentials. Following the development of the consolidation options, a list of required attributes and requirements to obtain were developed for each credential containing the unique sets of elements established by the credentials comprising each option. This set of elements specific to each option was then used to evaluate applicability for use by HazMat transportation workers in all modes. Table 3-15 contains the unique elements required of the applicant to obtain the credentials within a given option. This comparison provides the unique list of requirements necessary of a consolidated credential to replace the credentials comprising each option. In all, there are 40 elements that make up the unique requirements to obtain for a consolidated credential to replace Option 2. This assumes all elements currently existing and per- taining to the individual credentials would be necessary in a consolidated system. This list of elements provides a template for a consolidated credential with regard to the pieces of infor- mation to be collected from the applicant. In Table 3-16, the unique list of attributes is shown with the corresponding nota- tions of applicability for each option. There are 24 unique attributes applicable to consolidation; of course, each is accounted for in Option 2, which is com- prised of all candidate credentials. There is certainly variation in the applicable attributes per option; however, Options 2 and 4 are exactly the same. The sole difference between these two options is the lack of the USPS credential in Option 4, which did not include a single unique attribute beyond those already accounted for in the other candidate credentials within Options 2 and 4. Again, this complete list of unique attributes provides the minimum standard for a consolidated credential replacing each existing credential within Option 2. Finally, Table 3-17 includes the unique background checks for each option and corresponding notations of applicability. All but Option 1 contain all four background check processes noted. This similarity among security credentials provides a logical starting point for consolidation. As evidenced by the data, little-to-no change is required to the background check process should consolidation of the candidate credentials occur. It is important to note that although the processes are the same (in most cases), the disqualifying offenses are not. Therefore, this logical beginning is not without required compromise. Should consolidation occur, the disqualifying offenses would need to be standardized. This process could raise all appli- cants to the highest standard, theoretically increasing secu- rity systemwide. However, this would most certainly restrict 43 Table 3-14. Credential combinations evaluated as consolidation options. Credential Options Evaluated 1noitpOCIWT TWIC, MMD, SIDA, USPS, CAC Option 2 3noitpODMM,CIWT TWIC, SIDA, CAC, MMD Option 4

the applicant pool and dramatically reduce the labor force. Conversely, the standard could be set to the least common denominator, potentially lowering overall security, but increasing the applicant pool sufficiently to handle labor demand. Realistically, this process would result in some sort of middle ground. It is also possible that the variation in disqualifying offenses could be used to develop a tiered consolidated credential. The tiers would need to be defined by appropriate stakeholders based on risk analysis, labor requirements, and job function. It is impractical to establish tiers that could allow credential- holders to perform part, but not all, of their required job function. The options were evaluated to determine the strongest pos- sibility for success in consolidation. To that end, Option 2 as a consolidated credential would provide the broadest applicabil- ity. (This is expected because it is comprised of the most can- didate credentials.) However, the process of consolidation must consider more than just the broadest applicability with regard to credential elements and processes. It must also con- sider the cost of change. Each option (except Option 1) would require the consolidation of credentials issued by different agencies. The consolidation of personnel, facilities, and back- 44 Table 3-15. Unique requirements to obtain for consolidation. Option 1 2 3 4 Address Address History Aliases Character References Citizenship Information Copy of Driver’s License Date of Birth Drug Testing Education History E-Mail Address Employer Fax Number Employer's Address Employer's Name Employer's Phone Number Employment History Eye Color Fax Number Fingerprinting Full Name Hair Color Hearing Test Height Medical/Physical Examination Military Service National Driver Register Check Next of Kin Next of Kin E-Mail Address Next of Kin Phone Number Occupation Phone Number Place of Birth Preferred Notification Method Race Previous Screening within 12 months Security Threat Assessment Sex Social Security Number Sponsoring Agency Information Vision Test Weight Option 1 2 3 4 Access Level Address Authorization Agency Bar Code Citizenship Date of Birth Date of Expiration Date of Issue Dual Interface ICC Employer Endorsements Eye Color Full Name Hair Color Height If Found Issuing Location/Branch Magnetic Strip Photograph Signature Social Security Number Tamper-Resistant Features Unique Serial Number Weight Table 3-16. Unique attributes for consolidation. Option 1 2 3 4 Fingerprint-Based Criminal Records Check Name-Based Relevant Database Check Drug Test National Driver Register Check Table 3-17. Unique background check elements for consolidation.

ground processes, as well as the credentials themselves, would require certain costs. It is possible that in some cases the act of consolidation could result in cost savings associated with some aspect of the overall credential process. This information should be understood before a definitive decision could be made on the best course of action regarding consolidation. As is often the case, the costs associated with the various options for consolidation could significantly change the perspective of stakeholders, ultimately changing the ideal option from one to another. In addition to understanding the costs associated with potential consolidation it is important to understand the effect that consolidation could have on existing stakehold- ers, and the likelihood for successful adoption and use. In order to inform this discussion, it was necessary to evaluate policy impetus as it relates to the process of consolidating security credentials for persons who transport hazardous materials. Policy Implementation Analysis The following discussion draws upon organizational change, organizational learning, and policy implementation research, and presents a multiple-perspective analysis (i.e., organiza- tional, technical, and personal). Multiple-perspective analysis is designed to deal with ill-structured policy problems employing a systematic evaluation of policy solutions.(6) Organizational Perspective The characteristics of the organizations in question must be taken into account when policy changes are proposed. Organi- zational characteristics to be considered are impetus and authority, organizational form, and competitive isomorphism. Impetus and Authority. The impetus for policies and/or an organization can come from a variety of sources including federal legislation, rulemaking, executive authority, or local authority. Congress, through legislative action, can create the impetus for particular policies and/or the organization itself. Regulatory impetus refers to those policies that have been established by agencies through the rulemaking process. Exec- utive authority indicates the impetus originated with an exec- utive order. Local authority refers to those policies established by state, local, or regional special authority (for example, the establishment of a port authority and subsequent port oper- ating procedures). Table 3-18 provides an overview of the rel- evant credential, and its authority. Organizational Form. Jensen (44, p. 110) defines orga- nizational form as a particular organization type that has a specific policy purpose and mission. For example, the DHS implements policies related to homeland security. Jensen also notes that organizations tend to have an institutional basis or a technical basis, while often combining elements of both. Organizations with an institutional basis “are derived more from values and meanings of society and less on technical activities, efficiency, or rationality.”(44, p. 114) An example of an institution basis is a port when it operates to implement shipping policies. Institutional-based policy decisions may be contentious. As a result, policy changes may require resolution from the political system. Changes may need to be dictated by the legislator, which acts as the moderator of large-scale change (44). Without legislative intervention, proposed policy changes may face significant resistance. Organizations that have a technical basis tend to focus on efficiency or have a production basis. As Jensen notes, these agencies exist to fulfill a concrete need and to improve effi- ciency.(44) For example, departments of motor vehicles exist 45 Credential Impetus Authority )UL-AETEFAS,.e.i(95-901waLcilbuPlanoissergnoCTSAF Local Ports Local Authority Based upon state, local, or regional special authority (i.e., port authority) 01traPRFC64evitucexECMM 61-01straPRFC64dna641-101RFC33evitucexEDMM )UL-AETEFAS,.e.i(95-901waLcilbuPlanoissergnoCSUXEN Passport Executive and Congressional 8 USC 1185[b] and 22 CFR 53 )UL-AETEFAS,.e.i(95-901waLcilbuPlanoissergnoCIRTNES 4451,2451RFC94evitucexEADIS lanoissergnoCCIWT Maritime Transportation Security Act of 2002, Public Law 107-295 and 46, USC 70195 U.S. Department of Defense CAC Executive Homeland Security Presidential Directive 12 (HSPD-12) U.S. Postal Service Executive and Congressional USC 3301-3302; 5 CFR 5, 731, 732, 736; and Executive Orders 10450 and 105775 Table 3-18. Credentialing agency’s impetus and authority.

to implement and enforce motor vehicle policies. Technical needs may be internal to organizational units and may differ significantly among organizations. Continuing the state depart- ments of motor vehicle example, policies and procedures within each state may vary and may use differing technologies. Table 3-19 provides an overview of credentials and associated organizational forms. Technical Perspective The technical perspective considers the climate in which the organization exists, financing, risk, and technological trends. Organizational Climate. Organizational climate requires that one account for the intangible feelings of political power, institutional legitimacy, and social fitness. The competition for power and legitimacy may be manifest in difficulties in recon- ciling differing requirements of specific policies into a new set of standards and determining responsibility for the new policy. A number of agencies, in response to agential concerns, devel- oped the current credentials. As a result, the underlying justi- fications for these credentials vary. For the FAST, Local Ports, MMD, NEXUS, U.S. passport, SENTRI, SIDA, TWIC, and CAC, the underlying justification is security. For the MMC, the underlying justification is to ensure skill, knowledge, and secu- rity. For the USPS credential, the underlying justification is to ensure fitness for duty and security. Likewise, agency stakeholders hold certain expectations in regard to each credential’s function and administration. Changes to current policy may be viewed as a challenge of an organization’s power within the policy subsystem or as a chal- lenge to the organization’s legitimacy. To manage uncertainty, cross-functional teams should be included in the development of the new policy from the earliest stage possible. These cross- functional teams should represent members of all departments (e.g., management, data processing, information technology) 46 Table 3-19. Credential and associated organizational form. Credential Organizational Oversight Institutional or Technical Predominant Basis FAST Canada Border Service Agency and U.S. Customs and Border Protection Agency Technical—charged with enforcing customs and border policies Local Ports Local Authority Institutional—develops and implements policies beneficial to the operation of the local concern MMC U.S. Coast Guard Institutional—charged not only with providing for the national defense, but also with developing operational guidelines that are consistent with institutional norms MMD U.S. Coast Guard Institutional—charged not only with providing for the national defense, but also with developing operational guidelines that are consistent with institutional norms NEXUS U.S. Customs and Border Protection Agency Technical—charged with enforcing customs and border policies Passport Bureau of Consular Affairs (CA) Technical—as a unit of the Department of State, CA is charged with protecting the lives and interests of American citizens abroad and strengthening the security of U.S. borders through the vigilant adjudication of visas and passports SENTRI U.S. Customs and Border Protection Agency Technical—charged with enforcing customs and border policies SIDA Transportation Security Administration Technical—as a unit of DHS, charged with protecting the nation's transportation systems to ensure freedom of movement for people and commerce TWIC Transportation Security Administration Technical—as a unit of DHS, charged with protecting the nation's transportation systems to ensure freedom of movement for people and commerce U.S. Department of Defense Common Access Card U.S. Department of Defense Institutional—charged not only with providing for the national defense, but also with developing operational guidelines that are consistent with institutional norms U.S. Postal Service Independent executive agency established within the U.S. Constitution Technical—charged with the task of mail delivery

and organizations affected by the new policy. Consolidated credentialing efforts will require a number of agencies and departmental units to work together to address the needs of a variety of stakeholders. A brief summary is presented in Table 3-20. This list of stakeholders is meant to provide a macro-level view of the stakeholders that should be involved in credential consolidation discussions and efforts. Financing. Waldron notes that cost of change is a major barrier to the implementation of new policies.(45) Cost and financing concerns include the more tangible costs associ- ated with competition over scarce resources and customers. Examples of financial considerations include current and future policy revenue streams (or lack thereof); cost of equip- ment and technologies; cost of time to develop, test, and implement new policies; and training costs associated with new policies. Looking at only the cost of each credential, it can be seen that the consolidation of credentials may have a significant impact on the agency’s revenue generation stream (see Table 3-21). Risk. Risk refers to the balancing of policy details with financial constraints. Trust is also a consideration. Trust issues can manifest in the lack of trust between participating organi- zations or a lack of trust in the policy results. To address trust issues, the development and implementation of a consolidated credential will require that stakeholders work together to ensure that program needs are addressed, guidelines are established, and outcomes are met. Technology Trends. Technology trends require that one accounts for the testing of new systems, the continued useful- ness of current systems, and potential problems relating to the timing of the change to a new system and general coordination of that change. It is critical that policy change activities be coor- dinated in the overall policy network. There must be a clearly communicated understanding of the new operation system if implementations are to be limited. Additionally, organiza- tional units must demonstrate cooperation and a willingness to work together in order to facilitate a systemwide policy change. When making software and hardware decisions, users 47 Table 3-20. Credential stakeholders. Credential Credentialing Agency and Affiliated Agencies Credential User Stakeholders FAST Canada Border Service Agency and U.S. Customs and Border Protection Agency and U.S. Department of Homeland Security Supply-chain members including commodity shippers, truck drivers Local Ports Local Authority Individuals seeking access to ports including longshoremen, truck drivers, port employees, vessel crews, outer continental shelf facility workers, merchant mariners MMC U.S. Coast Guard Crewmembers of U.S. ships with a GRT of more than 100 tons MMD U.S. Coast Guard Crewmembers of U.S. ships with a GRT of more than 100 tons NEXUS Canada Border Service Agency and U.S. Customs and Border Supply-chain members including commodity shippers, truck drivers, crews of shipping Protection Agency and U.S. Department of Homeland Security vessels and airplanes, facility managers Passport Bureau of Consular Affairs (CA) and U.S. Department of State Individuals attempting to depart from or enter the United States SENTRI Canada Border Service Agency and U.S. Customs and Border Protection Agency and U.S. Department of Homeland Security Supply-chain members including commodity shippers, truck drivers SIDA Transportation Security Administration and U.S. Department of Homeland Security Individuals who need unescorted access to secure areas of airports and aircrafts, airport management, airlines and other shippers TWIC Transportation Security Administration and U.S. Department of Homeland Security Individuals seeking access to ports including longshoremen, truck drivers, port employees, vessel crews, outer continental shelf facility workers, merchant mariners U.S. Department of Defense CAC U.S. Department of Defense and U.S. Department of Homeland Security Members of the armed services, civilian employees, government contractors srodnevdnaseeyolpmelatsoPSPSUecivreSlatsoP.S.U

should compare packages, obtain feedback from current users, and work closely with the support personnel and line workers who will be the end-users of the technologies. The implementation of a consolidated credential will require the adoption of new hardware and software. As noted in the attribute overview, credentials may include bar codes, RFID, dual interface integrated circuit chips (ICC), and magnetic strips. The information contained in these technologies pro- vides not only a redundancy of visible information on the cre- dential, but also may incorporate biometrics not included anywhere else on the credential (e.g., the TWIC credential- holder’s fingerprint, which is available by accessing the ICC). Agencies have dedicated funding to establish the current tech- nologies to make and process the credentials and to maintain the data associated with the credentials. Each facility also incurs costs to accommodate the credentials. These costs not only include infrastructure costs, but also the costs associated with training employees on the new technologies. Personal Perspective Just as organizations may be resistant to change, individuals within those organizations may also be resistant to change. Resistance to change can be seen at all layers of the hierarchy— from management to front-line employees. When dealing with the consolidation of programs, the need to address the sources of resistance is paramount. Waldron identifies several sources of resistance including the fear of change, difficulty in chang- ing, fear of new technology, lack of belief in the changes, lack of patience for the benefits of change, concern for job security, and opposition to new tasks.(45) Waldron also identifies sev- eral methods for overcoming change. These methods include obtaining assistance from outside parties, formalizing proce- dures, initiating quality assurance policies, embracing a model conducive to continual modifications and supplemental changes, and training regarding the benefits of the change as well as for new tasks.(45) 48 Table 3-21. Credential stakeholders and associated costs. Credential Credentialing Agency and Affiliated Agencies Stated Credential Cost FAST Canada Border Service Agency and U.S. Customs and Border Protection Agency $50.00 00.001$drauGtsaoC.S.UCMM 00.001$drauGtsaoC.S.UDMM NEXUS U.S. Customs and Border Protection Agency $50.00 Passport Bureau of Consular Affairs (CA) and U.S. Department of State $100.00 SENTRI U.S. Customs and Border Protection Agency $122.25 SIDA American Association of Airport Executives $91.33* TWIC Transportation Security Administration $132.50 U.S. Department of Defense CAC U.S. Department of Defense Unavailable elbaliavanUSPSUecivreSlatsoP.S.U *Note: Arithmetic mean, see Appendix F.

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Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials Get This Book
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TRB’s Hazardous Materials Cooperative Research Program (HMCRP) Report 6: Feasibility of a Consolidated Security Credential for Persons Who Transport Hazardous Materials discusses the feasibility of consolidating several existing security credentials, which are necessary under current regulations and policies, into one credential for all transportation modes.

The report evaluates the credentialing system to identify duplicative elements and redundant costs and describes the acquisition process, the application elements, and the physical characteristics for each identified credential. In addition, the report identifies the elements of the vetting processes for each credential. The report includes an examination of four options for consolidation, which provides insight into the basic elements of a universally recognized security credential for HazMat transportation workers.

HMCRP Report 6 also identifies key challenges for consolidation of security credentials, such as impetus and authority, organizational climate, financing, risk, and technological trending.

An alternative method of consolidating background checks is identified as a possible intermediate solution for removing duplicative processes and redundant costs.

A PowerPoint presentation, which summarizes the report process and conclusions, is available for download.

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