Homeland Security Watch

News and analysis of critical issues in homeland security

August 27, 2009

How To Improve Homeland Security: A Universal Risk Assessment for America’s Railroads

Filed under: Infrastructure Protection,Risk Assessment — by Christopher Bellavita on August 27, 2009

America’s trains carry more than 12 million passengers every weekday.  There have been no successful attacks on US rail systems in recent history.  Globally, however, railway systems remain an attractive target for terrorists.

Between 1998 and 2003, there were more than 180 attacks on trains and related rail targets around the world.  Terrorists have attacked railway systems most dramatically in Mumbai, Moscow, Madrid, and London, killing hundreds and injuring thousands.

What are America’s railroads doing to prevent a similar attack?

In January 2009, DHS reported “that more than 75% of the nation’s major rail and bus systems aren’t meeting [voluntary] Homeland Security guidelines” established in 2007.   The same report, according to a story written by Frank Thomas, found that “96% of airlines are complying with security requirements.” [my emphasis]

I don’t know enough about rail security to know what to make of the comparative findings. But I do know that guidelines are not the same as requirements. As a TSA leader phrased it, there is no penalty for failing to comply with guidelines.

Two years ago, The RAND Corporation released “Securing America’s Passenger-Rail System,”  offering a framework for railroad security planning.  As far as I know, it remains the most comprehensive treatment of the vulnerabilities and threats faced by American railroads.

To understand railroad system vulnerability, RAND “identified 11 potential target locations (e.g., system-operation and power infrastructure) within a notional rail system and eight potential attack modes (e.g., small explosives).  These targets and attack modes were combined to produce 88 different attack scenarios of concern.”

Today’s guest blogger is a security executive with a major rail system.  Her idea about improving homeland security begins with a different kind of scenario.  She outlines a vulnerability created by the networked nature of America’s railroads, and suggests what can be done about it.

Here’s the scenario:

Assume that Rail Carrier A institutes specific security procedures based upon its own risk assessment. Rail Carrier B shares track with Carrier A but does not prioritize the trains entering A’s environment based upon A’s risk assessment.

Security measures on B’s trains are limited.  Because A and B trains operate simultaneously in the same environment it is possible that the security efforts of A are less effective because of B’s inadequate measures. Both Carriers are operating under individual risk assessments, but the inter-connectivity between the two carriers has not been adequately addressed.

Now, what to do about this vulnerability:

1. What one sentence best describes your idea about how to improve homeland security?

The Department of Homeland Security should conduct a universal rail transportation vulnerability assessment to effectively address national risk.

2. Describe the idea in more depth.

The Department of Homeland Security (DHS) through the Transportation Security Administration (TSA) requires rail transportation entities, both passenger and freight, to conduct vulnerability/risk assessments.  The TSA does not identify one methodology for conducting these assessments.   In order to better assess the vulnerability of the nation’s rail and mass transit systems, the TSA, as directed by the DHS, should conduct a universal rail risk/vulnerability study with one defined methodology to accurately assess the entire inter-connected national rail system.

In many areas track is shared by freight, regional and other passenger rail systems.  Although each of these entities conducts risk and vulnerability studies, they are not shared among the carriers or effectively evaluated from an overall homeland security perspective.

A universal approach would better reveal high risk locations and could assist individual carriers in determining how to effectively deploy limited resources. The risk and vulnerabilities can then be prioritized on a broad scale and evaluated to maximize the effective use of federally and otherwise funded security projects.

3. What problem does your idea address?

It is undeniable that rail, both freight and passenger systems, are key components of the United States’ critical infrastructure. It is also well known that the rail transportation sector is a preferred target for terrorists.  Independent risk assessments, which may not accurately reflect inter-connectivity, will not be effective in determining the actual vulnerability of our national rail system and, subsequently, assist in accurately deploying security resources.

4. If your idea were to become a reality who would benefit most and how?

The traveling public would be the primary beneficiary of a universal assessment.  A broad based evaluation of risk may increase security by placing the limited resources where they are most needed.

Individual rail companies have separate owners, budgets and priorities.  They add security measures and harden targets that are important to them as individual carriers.  This go-it-alone strategy may only result in pushing the terrorist to a less vulnerable target, instead of using a nationally defined risk to improve the security of the entire system.  Adding security improvements on a broader scale may deter a terrorist from attacking the transportation sector as a whole.

5. What are the initial steps needed to get the idea off the ground?

The DHS must take a more active role in the overall security of the rail system than it has to date and promulgate a federal regulation or directive.  Resources would be needed to define the risk methodology and to conduct this assessment in coordination with the rail carriers.

It is possible that there may be limited support for this new assessment from rail carriers because assessments have already been completed.  Consequently the value of what I am proposing may not be understood or accepted.  Funding to conduct the assessment is also a significant issue.

Individual next steps will include promoting the idea through the appropriate chain of command in the various Carrier groups, and obtaining permission to discuss the concept with an appropriate member of the TSA.

6. Describe the optimal outcome should your idea be selected and successfully implemented? How would you measure that outcome?

In the best case, all rail transportation would be universally assessed based upon the same methodology.  Security resources and funding awards would be deployed based upon these assessments.  Completing this universal assessment and resulting recommendations for a safer rail system could be a measure of success.

But the key to a safer rail will not be a report, but changes in rail security implemented because of the new assessment. The desired outcome will be to harden the entire rail system and make it a less attractive target for terrorists.

As in many cases, measuring the effectiveness of any security enhancement may not be possible.  But with a security approach derived from a universal rail sector risk assessment, we can achieve a new level of confidence in the security of America’s railroads.

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Comment by William R. Cumming

August 27, 2009 @ 8:41 am

The Hazardous Materials Transportation Safety Act also requires comprehensive updating since 9/11/2001! HAZMATS can expand expotentially the threat and risk!

See Title 49 US Code generally. And also Title 49 of the CFR!

Comment by Patrick Coyle

August 28, 2009 @ 11:10 am

Actually there have been some significant upgrades to HAZMAT security measures for rail shipments. See “Rail Transportation Security” 73 FR 72129-72180 (49 CFR 1520 and 1580) and “Enhancing Rail Transportation Safety and Security for Hazardous Materials Shipments” 73 FR 72181-72194 (49 CFR Parts 172, 174, and 209).

Comment by William R. Cumming

August 28, 2009 @ 2:48 pm

Thanks Patrick! And question–Does the NCP published at 40 CFR Part 300 also cover HAZMATS Transportation incidents/events? The reason I ask I understand that document is under comprehensive revision by EPA and Coasties assisted by a contractor! Last comprehensive update was 1994 before the March 1, 2003 startup [for real] of DHS!

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