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

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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)

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36 Table 3-9. (Continued). Merchant Mariner Document (MMD) (33) Authority Executive 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) 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

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37 Table 3-9. (Continued). 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. 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. 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. (continued on next page)

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38 Table 3-9. (Continued). 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 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.

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

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

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

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