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运输工人身份证阅读器要求的风险知情分析(英).pdf
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运输工人身份证阅读器要求的风险知情分析(英).pdf
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An FFRDC operated by the RAND Corporation under contract with DHS
HS AC
HS
AC
AC
HOMELAND SECURITY
OPERATIONAL ANALYSIS CENTER
Risk-Informed Analysis
of Transportation Worker
Identi cation Credential
Reader Requirements
JOSEPH C. CHANG, JAMES V. MARRONE, DAVID METZ, SEAN COLBERT-KELLY, MATTHEW A. DENARDO, KEITH GIERLACK, CHELSEA KOLB, RYAN
BAUER, DEVON HILL, KRISTIN J. LEUSCHNER
This research was published in 2022.
Approved for public release; distribution is unlimited.
iii
About This Report
To help it implement the final reader rule entitled “Transportation Worker Identification Credential
(TWIC)—Reader Requirements,” the U.S. Coast Guard (USCG) asked the Homeland Security Operational
Analysis Center (HSOAC) to estimate the population of the Maritime Transportation Security Act–regulated
facilities that the rule might affect; develop a transparent, objective risk assessment model for these facilities;
and conduct a cost–benefit analysis of the regulation.
This report describes our analytical efforts to address the three research areas mentioned above. Because
there is no database of Maritime Transportation Security Act–regulated facilities with all the requisite infor-
mation about certain dangerous cargoes that facilities handle in bulk, we resorted to other data sources, such
as the U.S. Environmental Protection Agency’s databases, an online survey, and interviews, to estimate the
facility population. For the facility risk model, we used the modeling approach for assessing potential con-
sequence included in the risk engine of the Cybersecurity and Infrastructure Security Agency’s Chemical
Facility Anti-Terrorism Standards (CFATS) program, harmonizing the TWIC and CFATS programs in con-
sequence assessment. Because there was no credible estimate for the probability of a transportation security
incident, we used a break-even analysis to assess whether the final reader rule is cost-effective.
This research was sponsored by the USCG Office of Standards Evaluation and Development and con-
ducted within the Strategy, Policy, and Operations Program of the HSOAC federally funded research and
development center (FFRDC).
About the Homeland Security Operational Analysis Center
The Homeland Security Act of 2002 (Section305 of Public Law107-296, as codified at 6U.S.C. §185) autho-
rizes the Secretary of Homeland Security, acting through the Under Secretary for Science and Technology,
to establish one or more FFRDCs to provide independent analysis of homeland security issues. The RAND
Corporation operates HSOAC as an FFRDC for the U.S. Department of Homeland Security (DHS) under
contractHSHQDC-16-D-00007.
The HSOAC FFRDC provides the government with independent and objective analyses and advice in
core areas important to the department in support of policy development, decisionmaking, alternative
approaches, and new ideas on issues of significance. The HSOAC FFRDC also works with and supports
other federal, state, local, tribal, and public- and private-sector organizations that make up the homeland
security enterprise. The HSOAC FFRDC’s research is undertaken by mutual consent with DHS and is orga-
nized as a set of discrete tasks. This report presents the results of research and analysis conducted under task
order 70Z02320FMSR04300, Risk-Informed Analysis of Transportation Worker Identification Credential
(TWIC) Reader Requirements.
The results presented in this report do not necessarily reflect official DHS opinion or policy.
For more information on HSOAC, see www.rand.org/hsoac. For more information on this publication,
see www.rand.org/t/RRA1687-1.
Acknowledgments
We want to acknowledge Kimberly Wilson, Jeffrey Horn, and their colleagues in the USCG Office of Stan-
dards Evaluation and Development; and Bradley Clare, Nicolette Vaughan, Andrew Meyers, and their col-
leagues in the USCG Office of Port and Facility Compliance for their strong support and expert guidance
Risk-Informed Analysis of Transportation Worker Identification Credential Reader Requirements
iv
throughout the study. Kathryn Clay and Jay Cruz of the International Liquid Terminals Association; Kimberly
Wise White, Jeffrey Sloan, and William Erny of the American Chemistry Council; and Jeff Gunnulfsen of
American Fuel and Petrochemical Manufacturers have been tremendously supportive by providing indus-
try perspectives and reaching out to their respective memberships to seek additional inputs. We are grateful
to the USCG Office of International and Domestic Port Security Assessment for providing the Maritime
Security Risk Analysis Model data. We thank Henry Willis and Victoria Greenfield of HSOAC for very
informative discussions about the proper interpretation of the results of a cost–benefit analysis. Comments
from AlisonK. Hottes of HSOAC, our informal reviewer, have greatly improved this report. EllenM. Pint,
EdwardW. Chan, and Katherine Tiongson, our formal HSOAC quality-assurance reviewers, have also kept
us grounded and provided helpful guidance. Rebecca Weir skillfully processed the U.S. Environmental Pro-
tection Agency’s Risk Management Plan data.
Finally, we want to express our sincere gratitude to Terry McClure of the Cybersecurity and Infrastruc-
ture Security Agency and Thomas Taylor of ABS Group for their generous support in providing technical
expertise in and conducting a massive number of simulations of the CFATS risk engine. Without their assis-
tance, this study would not have been possible.
v
Summary
S.1. Issue
The Transportation Worker Identification Credential (TWIC) program, jointly administered by the U.S.
Coast Guard (USCG) and the Transportation Security Administration (TSA), requires anyone accessing a
secure area at a Maritime Transportation Security Act (MTSA)–regulated facility, vessel, or outer continen-
tal shelf facility either to have a TWIC or to be escorted by someone with a TWIC.
1
Facilities must maintain
access control programs at secure areas to verify each person’s identity and business purpose. Until recently,
facilities could conduct these checks by inspecting TWICs visually; however, a 2016 USCG regulation, known
as the final reader rule on TWIC reader requirements, would require any facility that the USCG determines
to be of high risk to inspect TWICs electronically and verify the identities of credential holders using stored
biometric data. Final implementation of the reader rule has been delayed (from 2020) until May8, 2023, for
three categories of facilities that handle certain dangerous cargoes (CDCs) in bulk.
2
During the delay period,
the USCG wanted to reexamine the population of facilities subject to the reader rule delay and to reestimate
the costs and benefits of the TWIC reader rule.
The USCG asked the Homeland Security Operational Analysis Center, a federally funded research and
development center operated by the RAND Corporation for the U.S. Department of Homeland Security, to
conduct a risk-informed analysis to support the implementation of the final reader rule. The specific research
questions were as follows:
• How many facilities are subject to the reader rule delay?
• Is the final reader rule cost-effective for those facilities?
The researchers conducted three main tasks to answer the research questions:
1. We estimated the population of maritime facilities that handles CDCs.
2. We developed an objective, transparent risk model for these facilities.
3. We developed a revised cost–benefit analysis for the reader rule delay based on the population estima-
tion and the facility risk model.
Although many commodities are considered CDCs, only 43CDCs are authorized to be transported by
vessels in bulk, according to a 2020 USCG CDC job aid. Facilities that handle these 43CDCs in bulk are the
focus of this report.
1
For purposes of this report, facility refers to
[a]ny structure or facility of any kind located, in, on, under, or adjacent to any waters subject to the jurisdiction of the United
States and used, operated, or maintained by a public or private entity, including any contiguous adjoining property under
common ownership or operation. (33C.F.R. §101.105)
2
For purposes of this report, bulk refers to a “commodity that is loaded or carried without containers or labels and that is
received and handled without mark or count. This includes cargo transferred using hoses, conveyors, or vacuum systems”
(33C.F.R. §101.105).
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