Rules doomed to fail without adequate resources and strong enforcement
The Transportation Trades Department, AFL-CIO, filed comments in response to new rules regarding railroad and transit security proposed by the Transportation Security Administration (TSA) and the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration. Edward Wytkind, President of TTD, said the following:
“Any new rules for rail and transit security are toothless because there are simply not enough TSA personnel or resources to enforce them. There are more than 40,000 TSA personnel dedicated to aviation in this country. There are about 100 TSA personnel dedicated to surface transportation in this country.
“How vast a network is encompassed by the term ‘surface transportation’? Included is more than 140,000 miles of local, regional and national freight railroad track; 23,000 miles of passenger rail track; 7,100 miles of urban transit rail systems; 165,000 miles of bus routes; and more than 4 million miles of Interstate highway, national highway and other roads.1 It is ridiculous to think that 100 people could cover this much ground.
“The TSA is a major force in aviation, as it should be. But the TSA’s role in surface transportation security isn’t remotely proportional. Its extremely limited role is an abdication of responsibility. The TSA often doesn’t do the things it should and is notorious for missing deadlines set by Congress. But even if it proposes strong security regulations, we question whether it has the commitment to spend the resources needed to accomplish its objectives.
“Despite Congressional calls for mandatory security training, the TSA fails to require that all front-line rail and transit employees receive comprehensive, mandatory security training. This is a missed opportunity to significantly enhance security. Five years after 9/11, you’d think we could do better.
“The proposed new rules suggest that TSA will ‘provide guidance’ for railcar inspectors to identify improvised explosive devices and signs of tampering. Comprehensive training is needed in this case, not unspecified or vague guidance.
“The TSA also suggests that rail conductors add guarding certain hazmat deliveries to their long list of responsibilities. We disagree strongly with the expectation that train conductors or any operating employees should be held responsible for this task. Piling additional, extremely sensitive responsibilities on an overworked and fatigued workforce is irresponsible policymaking.”