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9 CHAPTER 2 Research Approach This research was done in a multi-phase approach. The Credential Synthesis main goal of Phase I was to understand the existing creden- The research team compiled all security credentialing lit- tialing system as it relates to persons who transport hazardous erature in the Virginia Tech Transportation Institute (VTTI) materials, and determine the feasibility of a consolidated cre- HazMat library. This effort was supplemented by a national dential within that system. This first phase involved the exam- and international review of Internet resources, academic arti- ination of the current credentialing processes at their basic levels cles, and other public information sources with the objective to understand each credential's elements (e.g., security attri- of determining the underlying credentialing processes and butes, related costs, time to acquire) and associated strengths regulatory requirements for each credential. and weaknesses. This elemental analysis approach provided To augment the information, the research team assembled the data blocks necessary for generating and evaluating a technical advisory group (TAG). The group was comprised consolidated credential options in Phase II. of seven members with varied experience in the different modes Phase II was dependent on the results of Phase I and the of transportation or credentialing. Each TAG member was feasibility of consolidating credentials. Phase II consisted of a selected because of a direct role or related experience with single task to develop potential options for consolidating cre- credentialing and is listed below with a brief description of dentials for persons who transport hazardous materials, and their relevance to this effort. evaluating the strengths and weaknesses associated with each potential option. Tasks were organized as follows (note, Task John Smith has applied for, and used, HazMat credentials 5 was to produce the interim report and is not considered and is familiar with the application process. part of the research approach for Phase I): Karen Chappell is responsible for the state issuance and regulation of HazMat credentials. Task 1 (Phase I) Lt. Sal Castruita is on the security team of the Virginia Port Identify credentials and credential elements. Authority. Task 2 (Phase I) Wiley Mitchell was selected because of his understanding Conduct time and cost analysis. and knowledge of the purpose of the legal aspects of cre- Task 3 (Phase I) dentialing for the Norfolk Southern Railroad. Conduct regulatory analysis. Jim Wilding was chief executive officer (CEO) of the Met- Task 4 (Phase I) ropolitan Washington Airports Authority and is aware of Determine feasibility of consolidation. the risks involved and the reasons for credentials that are Task 6 (Phase II) necessary in order to access commercial airports. Develop and evaluate options for consolidation. Walter Witschey is the current president of the Virginia Rail Policy Institute and has access to numerous individuals and organizations associated with the freight rail industry. Phase I Dale Bennett is the president of the Virginia Trucking Asso- The research team developed and followed the flow chart ciation and has access to carriers and drivers involved in shown in Figure 2-1 to complete Phase I tasks. After identify- HazMat shipping. ing the credentials, the research team analyzed data in three key areas: Elemental Analysis, Time and Cost Analysis, and A short biography of each member is provided in Appen- Regulatory Analysis. dix A.

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10 Task 1 Task 2 Task 3 Task 4 Figure 2-1. Research approach for Phase I. Elemental Analysis have applied for these credentials in the past; in one case, the research team actually completed the online application With a completed list of relevant credentials, the research process. For two of the identified credentials, the Commercial team focused on identifying the elements of each. Elements are Driver's License (CDL)-HME and SIDA, the Code of Federal individual pieces of information used to acquire a credential, Regulations (CFR) was used to capture the minimum require- or contained within a credential to communicate the neces- ments. These federal minimums were used to provide a com- sary information to authenticate the identity of the credential mon denominator because each credential is handled by holder. Examples of elements are full name, address, access multiple issuing agencies (i.e., the states for a CDL-HME, and level, date of birth, photograph, and biometric attributes. To the airports for a SIDA). identify the elements, the research team focused on two key To obtain the attribute elements, the research team used a sources--the application for, and a representation of, the actual combination of photographs of credentials, actual creden- credential. tials, and written descriptions of credentials to identify each The application for each credential was used to determine attribute element on each credential. The collected elemental the requirements-to-obtain elements for that credential. Many data were placed in matrices to visually represent the data and of the credentials' applications were readily available on the to track gaps in the data throughout the progression of the issuing agencies' Web sites. However, the research team also research. This added a level of redundancy in the research obtained more obscure applications through companies that approach to ensure all available data were captured.

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11 Time and Cost Analysis credentials were federally issued, therefore, a single cost was associated with each. However, the CDL-HME is a state-issued Although time and costs both provide an understanding of credential and its cost varies by state. These data were publicly the burden to acquire security credentials, it was necessary to available from each state and placed into the matrix along with perform two separate data collection efforts. First, the research the federally issued credentials. The SIDA costs are designated team developed a questionnaire to collect time-related data by the issuing airport authority and, due to variability, are cap- from actual credential holders. Second, the research team col- tured as a mean of several agency-reported costs in the cost lected pricing data from each issuing agency related to each results matrix. credential. Regulatory Analysis Consolidated Credential Questionnaire To fully understand the credentialing process, the team Since this was an examination of several security credentials researched the regulatory authorities, programs, and policies, across many transportation modes, a survey was designed that and any applicable exemptions for each credential. This was would allow for the analysis of the credentials themselves, as done by a review of the CFR and the United States Code well as the use of the credentials across modes. The resulting (U.S.C.), where applicable to each credential. When necessary, survey addressed the following modes: air, highway and tractor- local regulations were consulted to understand the authorities trailer, marine, and rail. Additionally, the following security for credentials that are not federally issued. After identifying credentials were explored: the authorities and programs associated with each credential, the team investigated policy- and program-specific Web sites. CDL-HME, Furthermore, where necessary, the research team contacted rep- TWIC, resentatives of the credential-issuing agencies for clarification FAST, or additional information. Florida Uniform Port Access Credential (FUPAC), Merchant Mariner Credential (MMC), SWOT Analysis Merchant Mariner Document (MMD), Merchant Mariner License (MML), A strengths, weaknesses, opportunities, and threats (SWOT) NEXUS, analysis is designed to aid in the strategy decisions related to Secure Electronic Network for Travelers Rapid Inspection change in an organizational effort. This technique was used (SENTRI), and to analyze the advantages and disadvantages of a consolidated SIDA. and a non-consolidated security credentialing approach for persons who transport hazardous materials. The advantage The questionnaire was developed to ensure that the broadest to the SWOT analysis is the defined manner in which the data range of responses could be accommodated. This approach are examined, ensuring analysis from both internal (i.e., pro- provided an understanding of the time required to obtain the cessing of the credential) and external (i.e., use of the creden- aforementioned credentials. tial) points of view (Figure 2-2). The research team used the The questionnaire was created through collaboration with the TAG. During the developmental stage, the VTTI team conferred several times with the TAG to discuss questionnaire design and format. Discussions ranged from general question- naire goals and outlines to specific question methodology. Throughout the process, the team members exchanged ques- tionnaires and ideas in order to determine the best approach for obtaining the desired information. Credential Costs To collect the credential cost data, the research team col- lected the most up-to-date pricing information available using data from the Web sites of the issuing agencies. These data were organized by credential and placed into a matrix similar to those used for the elemental analysis. Many of the identified Figure 2-2. SWOT analysis.