Department of Homeland Security 

Office of Inspector General 

Effectiveness of TSA's Surface 


Transportation Security Inspectors
 

OIG-09-24 February 2009 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

 February 5, 2009 

Preface 

The Department of Homeland Security Office of Inspector General was established by 

the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector 

General Act of 1978. This is one of a series of audit, inspection, and special reports 

prepared as part of our oversight responsibilities to promote economy, efficiency, and 

effectiveness within the department. 

This report addresses the strengths and weaknesses of the Transportation Security 

Administration’s Surface Transportation Security Inspectors. It is based on interviews 

with employees and officials of relevant agencies and institutions, direct observations, 

and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all who contributed to the preparation of this report. 

Richard L. Skinner 


Inspector General 

Table of Contents/Abbreviations 


Executive Summary.............................................................................................................1
 

Background..........................................................................................................................2
 

Results of Review ................................................................................................................5
 

Surface Inspector Assessment and Domain Awareness Initiatives 

Have Been Effective ...................................................................................................5 


Recommendations........................................................................................................12 


Management Comments and OIG Analysis ................................................................12 


Additional Surface Inspectors Are Needed to Perform Future Tasks and Enhance 

Understaffed Field Offices........................................................................................13 


Recommendations........................................................................................................16 


Management Comments and OIG Analysis ................................................................17 


Command Structure Inhibits Surface Inspector Effectiveness ....................................18 


Recommendations........................................................................................................23 


Management Comments and OIG Analysis ................................................................23 


Appendixes 

Appendix A: Purpose, Scope, and Methodology........................................................26 


Appendix B: Management Comments to the Draft Report ........................................27 


Appendix C: Freight Rail Security Action Items........................................................33
 

Appendix D: Major Contributors to this Report.........................................................36 


Appendix E: Report Distribution................................................................................37 


Abbreviations 

AFSD Assistant Federal Security Director 


BASE Baseline Assessment for Security Enhancement 


DHS Department of Homeland Security 


FSD Federal Security Director 


hazmat hazardous materials 


SAI Security Action Item
 

STSIP Surface Transportation Security Inspection Program
 

TIH Toxic Inhalation Hazard 


TSA Transportation Security Administration 


TSI Transportation Security Inspector – Surface 


TSOC Transportation Security Operations Center 


VIPR Visible Intermodal Prevention and Response 

OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Aviation and Transportation Security Act gave the 

Transportation Security Administration (TSA) the responsibility to 

secure all modes of transportation in the United States. TSA created 

the Surface Transportation Security Inspection Program in 2005 to 

provide oversight and assistance to surface transportation modes. 

Currently, the program’s Transportation Security Inspectors – 

Surface act as assessors, advisors, and liaisons, primarily in the mass 

transit and freight rail modes. In the future, TSA also expects the 

inspectors to enforce regulations and monitor progress on grant 

projects. Additionally, they may eventually work in pipeline and 

highway modes. The Implementing Recommendations of the 9/11 

Commission Act of 2007 (the 9/11 Commission Act) mandated that 

we review the performance and effectiveness of the Transportation 

Security Inspectors – Surface, review whether there is a need for 

additional inspectors, and make other recommendations based on 

our analysis. 

TSA is improving security in the mass transit and freight rail 

modes through the inspection program. Inspectors help bus and 

passenger rail stakeholders identify security gaps through Baseline 

Assessment for Security Enhancement reviews. They help reduce 

the risk that Toxic Inhalation Hazard shipments pose to High 

Threat Urban Areas through Security Action Item reviews. They 

increase TSA’s domain awareness by producing station profiles 

and by acting as liaisons between the Transportation Security 

Operations Center and transportation systems. They also 

participate in Visible Intermodal Prevention and Response 

exercises, which provide an unannounced, high-visibility presence 

in a mass transit or passenger rail environment. 

TSA faces important challenges in improving the effectiveness of 

the Transportation Security Inspectors – Surface. As TSA expands 

its presence in non-aviation modes, it must look critically at how it 

is deploying resources. TSA must continue to assess how planned 

exercises can better use the inspectors and their activities. The 

program appears understaffed for the long term and an aviationfocused command structure has reduced the quality and morale of 

the workforce. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 1 
Background 

The Aviation and Transportation Security Act gave the Transportation 

Security Administration (TSA) the responsibility to secure all modes of 

transportation.1 In 2005, TSA created the Surface Transportation Security 

Inspection Program (STSIP) to provide oversight and assistance to surface 

transportation modes. Transportation Security Inspectors – Surface (TSIs) 

have the authority to enforce security regulations and to help stakeholders 

improve their security in the surface modes, which include the mass 

transit, freight rail, highway, and pipeline sectors. In May 2008, TSA 

began expanding its force from 100 inspectors at 19 field offices to 175 

inspectors at 54 field offices. 

Although TSIs were originally created to be compliance inspectors for 

mass transit and freight rail, Congress and the Department of Homeland 

Security (DHS) have enacted several regulations, directives, and 

recommendations that have expanded TSI responsibilities (see figure 1 

below). Currently, TSIs act as assessors, advisors, and liaisons, primarily 

in the mass transit and freight rail modes. In the future, TSA also expects 

TSIs to enforce regulations and help monitor the progress of grant 

projects. Additionally, TSIs may eventually work in pipeline and highway 

modes. 

In mass transit systems, TSIs’ primary responsibility is to perform 

Baseline Assessment for Security Enhancement (BASE) reviews. TSIs 

collect detailed information regarding a bus or mass transit rail system’s 

implementation of TSA and Department of Transportation recommended 

security measures, and this information aids TSA in allocating transit 

grant funds. TSIs help increase TSA’s knowledge of bus and rail systems 

by responding to security incidents and by producing detailed profiles of a 

station’s security features. TSIs act as regional liaisons to transit system 

managers and security directors, and can discuss their use of grant funds. 

They also participate on Visible Intermodal Prevention and Response 

(VIPR) teams, which provide an unannounced, high-visibility presence in 

a mass transit or passenger rail environment. 

In the freight rail mode, TSIs perform Security Action Item (SAI) reviews 

of freight railroads’ compliance with TSA and Department of 

Transportation recommended security measures for the safeguarding of 

Toxic Inhalation Hazard (TIH) shipments. TSIs interview employees and 

perform onsite assessments of freight rail yards to observe operations. 

1 49 U.S.C. 114(d). 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 2 
 

TSIs inspect loaded TIH shipments in High Threat Urban Areas, and 

record their location and how long they were left unattended. 

Figure 1. Regulations, Directives, and Recommendations on TSI Roles 

Documents Outlining the Role of TSIs 

October 18, 2004: Department of Homeland Security Appropriations Act of 2005. 

Established the Surface Transportation Security Inspection program by supporting the 

deployment of up to “100 federal rail compliance inspectors.” 

January 4, 2005: Department of Homeland Security Appropriations Act of 2006. 

Amended inspector’s compliance role, directed rail inspectors to “identify coverage 

gaps” in security. 

December 21, 2006: TSA Rail Security Regulations (pending final approval). 

Established TSA’s authority to access transit systems and their records without advance 

notice. 

May 21, 2007: TSA’s Transportation Sector Specific Plan. Set forth inspectors’ roles 

as advisors, assessors, and liaisons in the mass transit and freight rail modes. Inspectors 

are to conduct freight rail and mass transit security reviews, and participate in Visible 

Intermodal Prevention and Response teams. 

August 3, 2007: Implementing Recommendations of the 9/11 Commission Act of 

2007. Defined the inspector’s domain as surface, including bus, highway, and pipeline 

modes. Gave inspectors the ability to issue citations in the event of stakeholder 

noncompliance with regulations. 

June 2008: TSA’s Administration and Coordination of Mass Transit Security 

Programs (DHS Office of Inspector General report). Recommended that TSIs 

provide TSA updates on the status of grant projects. 

TSIs serve as field personnel for numerous TSA components (see 

figure 2). TSA’s Transportation Sector Network Management, which sets 

policy over all modes of transportation and formulates security strategies, 

relies heavily on TSIs to assist with stakeholder relations and security 

assessments. The Office of Law Enforcement operates the VIPR program 

in which TSIs participate. The Transportation Security Operations Center 

(TSOC) uses TSIs to respond to security incidents on surface modes and 

gather first-hand information. Within TSA’s Office of Security 

Operations, the Compliance Program at headquarters manages TSI 

priorities, while the Federal Security Directors (FSDs) in the field manage 

the TSIs themselves. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 3 
Figure 2. Organization of TSI Responsibilities 

TSIs are organized into 12 primary field offices and 42 satellite offices 

(see Figure 3). Each primary field office contains a supervisory TSI, 

designated as an Assistant Federal Security Director – Surface (AFSD– 

Surface), who is responsible for inspectors in their office and provides 

some oversight for inspectors in nearby satellite offices. TSA generally 

deploys TSIs in cities with a major mass transit system or significant 

freight rail activity. 

Figure 3. TSI Field Offices 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 4 
Results of Review 

The Aviation and Transportation Security Act of 2001 gave TSA authority 

and responsibility for security on all modes of transportation. Since 2005, 

TSA has increased its efforts to mitigate the vulnerability of mass transit 

and freight rail systems across the United States with the STSIP. The 

STSIP has been effective in its assessment and domain awareness 

initiatives. As TSA expands its presence in non-aviation modes, it must 

look critically at how it is deploying resources. TSA needs to assess how 

VIPR exercises can better use TSIs and their activities. The program 

appears understaffed for the long term, and an aviation-focused command 

structure has reduced the quality and morale of the workforce. 

Surface Inspector Assessment and Domain Awareness Initiatives 

Have Been Effective 

TSIs’ assessment and domain initiatives have been effective and helped 

the program achieve many of its goals. TSIs are successfully improving 

security through BASE assessments, SAI reviews, and liaising between 

the TSOC and transportation systems. TSIs contribute to VIPR exercises, 

but TSA could do more to incorporate TSI activities with these exercises. 

BASE Assessments 

In the mass transit mode, TSIs perform BASE assessments that 

help bus and passenger rail stakeholders identify security gaps. A 

BASE assessment is composed of a series of interviews involving 

more than 190 security questions. Stakeholder responses receive 

numerical values and, based on these scores, the mass transit 

agency receives an overall score for each of TSA’s Six Transit 

Security Fundamentals (see figure 4). To validate responses, TSIs 

review documents, question personnel, and observe security 

measures within the transit system. During a BASE review, TSIs 

frequently work with the local agency security director to create or 

improve plans and protocols, and advise stakeholders on ways to 

address vulnerabilities. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 5 
Figure 4. TSA’s Six Transit Security Fundamentals 

TSA’s Six Transit Security Fundamentals 

1. Protection of high-risk/high-consequence, underwater/underground assets and 

systems. 

2. Protection of other high-risk/high-consequence assets identified through 

system-wide risk assessments. 

3. Use of visible, unpredictable deterrence. 

4. Targeted counterterrorism training for key frontline staff. 

5. Emergency preparedness drills and exercises. 

6. Public awareness and preparedness campaigns. 

TSA uses BASE assessments to increase its awareness of the 

Nation’s mass transit security posture. TSA also can set policy 

goals, identify areas for improvement, and formulate 

recommendations. As a result of BASE assessments, TSA has 

produced 55 Smart Security Practices, which give specific 

examples of transit systems that have implemented best practices. 

TSA plans to use BASE assessments to help formulate future 

security regulations and allocate asset-specific grants. 

Although BASE assessments are voluntary, they have led to 

security improvements in the mass transit systems reviewed. TSIs 

have performed 79 BASE assessments of the top 100 transit 

agencies. As of May 2008, TSIs have revisited two systems. The 

average scores of revisited systems show improvement in five of 

the six Transit Security Fundamentals (see figure 5). 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 6 
Figure 5. Transit Systems’ BASE Scores for TSA’s Transit Security 

Fundamentals 

100 

90 

80 

70 

60 Initial 

Assessment 

Score 50 Revisit 

40 

30 

20 

10 

0 

#1 #2 #3 #4 #5 #6 

Transit Security Fundamental 

SAI Reviews 

In the freight rail mode, TSIs perform Security Action Item 

reviews focused on reducing the risk that TIH shipments pose to 

High Threat Urban Areas. TIH refers to hazardous materials 

(hazmat) that can cause serious harm or death through inhalation. 

These materials, most commonly chlorine gas and anhydrous 

ammonia, have various uses and are frequently transported in large 

tank cars (see figure 6). The department has identified TIH 

materials as high risk because, in contrast to normal hazmat, an 

accidental or intentional airborne release has the potential to harm 

large, widespread populations. In November 2006, Secretary 

Chertoff set a goal to reduce the risk posed by transporting TIH by 

rail in High Threat Urban Areas by 50% in 2008. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 7 
Figure 6. Chlorine Tank Car 

To evaluate freight rail risks, TSA created a five-phase SAI 

assessment program. In Phases I-III, TSIs collect data to assess 

freight railroads’ implementation of 24 recommended security 

practices (see appendix C). TSIs evaluate a freight company’s 

security systems and plans, employee security and identification 

procedures, and other practices. In Phases IV-V, TSIs visit freight 

railroad locations to assess employee TIH awareness, verify the 

location of loaded TIH cars, and determine whether loaded cars are 

attended. TSA uses the data to calculate the risk posed by TIH in a 

given High Threat Urban Area. 

As a result of SAI review, TSIs make recommendations to 

stakeholders whose compliance is voluntary. TSA and TSIs 

encourage freight rail operators to expedite the movement of trains 

transporting rail cars carrying TIH materials, establish secure 

storage areas, position cars where the most practical protection can 

be provided, and reduce the amount of time that TIH cars are 

stationary or unattended. TSIs reported that stakeholders are 

cooperative and welcome recommendations that improve security. 

TSA officials said that information gathered from SAI reviews will 

drive the formulation of regulations. One regulation pending 

would require rail stakeholders in High Threat Urban Areas to 

enhance their chain of custody and control measures for TIH.2 If 

the regulation is approved, TSA could impose fines for 

noncompliance through an administrative process based on the 

results of its inspections. 

2

 49 CFR 1580 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 8 
The SAI review process has led to a reduction in the risk posed to 

High Threat Urban Areas. As of May 2008, TSIs have performed 

more than 3,000 SAI reviews of 500 freight rail facilities in 60 

High Threat Urban Areas. The results of the reviews showed that 

TIH cars were left unattended 13% fewer hours and overall risk 

was reduced by 54%. TSA officials report that they expect to 

maintain this reduction and achieve the Secretary’s goal of 

reducing current risk by 50%, by the end of 2008. 

Aiding Security Incident Response 

TSIs are enhancing TSA’s domain awareness for incident response 

by responding to information requests from the TSOC and 

producing station profiles. In the event of a security incident or 

other emergency, TSIs provide specific, local information for 

headquarters personnel. During these incidents, TSIs act as a liaison 

between the TSOC and the surface transportation systems. TSOC 

officials said that before the creation of the STSIP, it was difficult 

for them to collect incident information in the surface domain. 

The TSOC relies on the TSIs to provide rapid, accurate situational 

awareness during a surface transportation emergency. TSIs 

maintain relationships with more than 2,000 stakeholders 

nationally, including transit systems, freight rail operators, local 

law enforcement, and other stakeholders. TSOC representatives 

can contact a TSI at any hour, and can request that the TSI contact 

the appropriate local officials who have firsthand knowledge of the 

incident. The TSOC also can request that the TSI respond to the 

scene of an incident to ensure timely and accurate information 

reporting. Officials at the TSOC said that there are roughly ten 

incidents daily in which they rely on the TSIs to provide 

information. TSIs have been very successful in providing 

requested information: TSOC officials report a 100% response rate 

to their information requests. 

TSIs also produce station profiles that emergency responders can 

use to understand the layout of a mass transit station. These 

detailed reports catalog a station’s specific physical characteristics 

and security elements. Each profile includes photographs, maps, 

and points of contact. As of June 2008, TSIs have profiled 1,810 

of the approximately 3,600 mass transit stations in the United 

States. TSIs generally profile the most critical stations first. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 9 
Visible Intermodal Prevention and Response Teams 

TSIs participate in VIPR exercises, which provide an 

unannounced, high-visibility presence in a mass transit or 

passenger rail environment. TSIs mostly act as patrollers who 

monitor suspicious activity and whose presence may deter terrorist 

activity. In some locations, the AFSD–Surface coordinates the 

exercise with the local mass transit stakeholder. In other locations, 

TSIs informally educate other VIPR participants about the surface 

mode or an individual transit system. 

TSIs add value to VIPR exercises, but not as much as other 

participants (see figure 7). TSIs have less training and experience 

in behavioral detection than Behavior Detection Officers and, 

unlike Federal Air Marshalls or transit police, have no law 

enforcement authority. Unlike Transportation Security Officers or 

canine teams, TSIs have no training in passenger screening and are 

unable to detect explosives. However, TSIs are usually more 

familiar with a transit system than many participants and do fulfill 

a VIPR deployment’s ultimate purpose of providing a visible, 

unpredictable presence in a mass transit environment. 

Figure 7. VIPR Participants and Capabilities 

VIPR 

Participant 

TSIs 

Visible 

Presence 

Yes 

Behavior 

Detection 

Some 

Domain 

Familiarity 

Yes 

Arrest 

Authority 

No 

Explosives 

Detection 

No 

Screening 

Capability 

No 

Transportation 

Security 

Officers 

Yes Some Some No No Yes 

Behavior 

Detection 

Officers 

Yes Yes Some No No Yes 

Federal Air 

Marshalls 

No 

(covert) Yes Some Yes No No 

Canine Teams Yes Some Yes No Yes No 

Transit Police Yes Some Yes Yes No No 

In May 2008, TSA began hiring 75 new TSIs that were specifically 

appropriated for participation in VIPR teams. However, to 

maximize these resources, new hires will not participate 

exclusively in the VIPR program. Instead, TSA will implement a 

program-wide increase in TSI VIPR activity, resulting in 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 10 
participation equivalent to that of 75 full-time employees. The 

STSIP plans to increase the time that TSIs spend on VIPRs from 

approximately 2% to 25%. 

The STSIP will have difficulty meeting this goal. TSA’s Office of 

Law Enforcement, not the STSIP, primarily initiates and controls 

VIPRs. In a given month, the Office of Law Enforcement plans 

approximately 15 VIPR exercises, which equals about 120 hours of 

monthly VIPR activity. With 175 inspectors, the STSIP has 

approximately 28,000 total man-hours of activity each month. Even 

if ten TSIs attended every VIPR exercise for a full day, the STSIP 

would spend only 1,200 hours or 4% of its time on VIPR exercises. 

The Office of Law Enforcement does not operate enough VIPRs for 

TSIs to dedicate 25% of their time to this activity. 

TSA is working to integrate TSI initiatives with VIPR operations. 

Although the VIPR program Concept of Operations states that 

VIPR exercises should involve “utilizing screening, inspections 

and law enforcement in coordinated activities,” the TSIs’ role is 

limited to planning, educating, and patrolling. TSIs report that 

they feel underutilized during exercises. 

TSA would benefit if VIPR exercises integrated additional TSI 

activities and expertise that do not constitute regulatory 

compliance or comprehensive inspections. VIPRs should use the 

TSIs’ professional strengths while educating and familiarizing 

other VIPR participants about the surface modes. Additionally, 

with a significant portion of the TSIs’ time dedicated to VIPR, it 

may be necessary for the STSIP to integrate its activities with 

VIPR exercises to complete many of its tasks. 

We recognize that there are challenges in planning VIPR exercises. 

VIPR exercises have a designated coordinator, and exercises can 

involve weeks of planning. Transit systems have specific 

agreements with TSA on how VIPR exercises will be carried out 

and some systems have not yet approved them. VIPR coordinators 

are often unfamiliar with the nature of TSI activities. However, in 

response to our draft report, TSA expounded on the potential role of 

TSIs and how VIPR exercises might better integrate TSI resources. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 11 
Recommendations 

We recommend that the Administrator of the Transportation 

Security Administration: 

Recommendation #1: Assess how VIPR exercises can better use 

TSI resources and initiatives, then develop and execute a plan to 

conduct VIPR exercises that integrate TSI activities. 

Management Comments and OIG Analysis 

TSA provided written comments on our draft report. We evaluated 

these comments and have made changes where we deemed 

appropriate. Below is a summary of TSA’s written response to the 

report’s first recommendation and our analysis. A copy of TSA’s 

complete response is included as appendix B. 

TSA’s Comments to Recommendation #1: 

TSA partially concurred with the recommendation. TSA agreed 

that TSIs and their unique expertise in mass transit and rail should 

be integrated into VIPR planning and deployment. TSA stated that 

it has addressed the potential role of TSIs in its VIPR Team 

Capabilities and Operational Deployment guide. TSA did not 

agree that TSIs’ comprehensive inspection activities, such as 

BASE and SAI reviews, should be integrated into VIPR 

operations. TSA considered that doing so would fundamentally 

alter the nature and meaning of VIPR operations. TSA stated that 

VIPRs are intended to supplement existing security activities at a 

mass transit or passenger rail agency by randomly and 

unpredictably integrating TSA’s capabilities for an added deterrent 

effect. 

OIG Analysis: We consider TSA’s actions generally responsive 

to the recommendation. We concur with TSA’s intentions to 

expand TSIs’ role in planning and deployment. In its action plan, 

TSA should describe how it is encouraging VIPR coordinators to 

use TSIs for these and other activities, provide evidence that TSIs 

are participating in them, and document their progress in meeting 

participation goals. 

We agree that the integration of regulatory inspections by TSIs 

would alter the nature and meaning of VIPR operations. We also 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 12 
acknowledge the conflicting purposes of simultaneously 

conducting an operation and a full BASE assessment or a 

regulatory compliance inspection, should regulations be enacted. 

Based on TSA’s response, we clarified these points in the report’s 

discussion of VIPR teams. 

TSA has stated, and various documents support, its intentions to 

expand the role of TSIs in VIPRs and meet ambitious participation 

goals. The VIPR Concept of Operations and aforementioned 

deployment guide indicate that TSA is taking appropriate action. 

The VIPR Concept of Operations states that VIPR operational 

capabilities are law enforcement, screening, and inspection. The 

guidelines address the potential role of TSIs and identify 

observation and reporting, and collaborative efforts with transit 

and rail system officials to enhance their security baseline, as well 

as several other skills and capabilities that TSIs can bring to VIPR 

deployments. 

TSA can expand the role of TSIs even when they do not perform 

thorough or regulatory inspections. For example, TSIs are wellpositioned to carry out station profiles and physical verification 

during a VIPR operation. TSA will be challenged to sufficiently 

integrate TSIs to meet participation goals. Beyond advanced 

planning and passive observation, we are not clear to what extent 

TSA is willing to ask TSIs to support VIPR operations. We urge 

TSA to continue to look critically at how TSIs fit within the VIPR 

mission. 

This recommendation is Resolved – Open. 

Additional Surface Inspectors Are Needed to Perform Future 

Tasks and Enhance Understaffed Field Offices 

TSA would benefit from expanding the TSI workforce to handle new 

duties and to augment thinly staffed field offices. The 9/11 Commission 

Act gave TSIs the authority to perform regulatory compliance inspections 

and to perform their duties in all surface modes. Additionally, our June 

2008 report, “TSA’s Administration and Coordination of Mass Transit 

Security Programs,” recommended that TSIs play a greater role in TSA’s 

grant programs. 

With a current force of approximately 100 inspectors, TSIs are almost 

exclusively used as assessors in the mass transit and freight rail modes. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 13 
175

 

 

1000

1350

Although TSA will hire 75 additional inspectors in 2008, it is dedicating 

this increase in manpower to VIPR and is thinly deploying them across 34 

new field offices. This will put field offices at risk because they will be 

inadequately staffed to carry out current assessment duties or future 

compliance duties when one inspector is unavailable. 

TSA has not determined how many inspectors it needs for its future duties, 

although it has requested an additional 102 inspectors for FY 2010. The 

TSI force is small compared to other federal agencies with inspectors (see 

figure 8). The Department of Transportation employs approximately 

1,350 inspectors to perform safety inspections for the freight rail, pipeline, 

and highway modes, and the Coast Guard has roughly 1,000 inspectors to 

perform safety and security inspections for the maritime mode. 

Figure 8. Federal Safety and Security Inspection Forces for Surface Modes 

Federal Highway and Motor Carrier Safety Administration: 800 Inspectors Department of Federal Railroad Administration: 400 Inspectors 

Pipeline and Hazardous Material Safety Administration: 150 Inspectors Transportation Federal Transit Administration: 0 Inspectors 

Safety 

US Coast Guard Inspectors 

Safety and Security 

Transportation Security Administration Inspectors 

175 

Surface
 

Security
 

Inspectors
 

Surface Assessments and Regulatory Compliance 

Pending TSA rail regulations will require enforcement by TSIs. 

The proposed regulations would require rail entities to designate a 

security coordinator, report significant security incidents to TSA, 

and provide a secure chain of custody for hazmat. TSA officials 

said that they are waiting for the regulations to be published before 

reviewing whether the current force is adequate. 

TSIs have had little interaction with the pipeline industry, but TSA 

plans to use inspectors in this mode in FY 2009. The 9/11 

Commission Act requires that TSA review the 100 most critical 

pipeline operators. With only 11 employees, officials at TSA’s 

Pipeline Division said that they do not have the manpower to 

comply with the 9/11 Commission Act or enforce future 

Surface 

1,350 

Marine 

1,000 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 14 
regulations. A senior TSA official said that TSIs will be used to 

meet the requirements of the 9/11 Commission Act and other goals 

of the Pipeline Division in 2008 and 2009. 

TSA also is planning to assign responsibilities to TSIs in the 

highway and motor carrier modes. The 9/11 Commission Act 

requires that TSA perform a number of highway-related activities, 

including assessing the security risk of the trucking industry, 

documenting hazmat routes, and tracking sensitive materials. 

Additionally, officials from TSA’s Highway and Motor Carrier 

Division expressed interest in using TSIs for Corporate Security 

Reviews and enforcing future regulations. However, TSA has yet 

to develop plans to use TSIs in this mode. Highway and Motor 

Carrier Division officials said that highway regulations would 

require “hundreds of compliance inspectors.” 

With the exception of grant oversight, TSA officials believe there 

is little need for TSIs in the maritime transit mode. The U.S. Coast 

Guard has primary responsibility for security in this mode and has 

1,000 marine safety and security inspectors who enforce security 

regulations and conduct inspections. 

Grant Oversight 

Three surface-related grant programs may require TSI participation. 

TSA administers the Transit Security Grant Program, Trucking 

Security Grant Program, and Intercity Bus Security Grant Program. 

In FY 2008, DHS awarded grants for these programs in excess of 

$415 million. TSIs develop considerable asset-specific information 

through routine assessments and consultation with surface 

stakeholders. TSIs can physically verify the use of grant funds 

through direct observation, and TSI assessments can provide 

transparent substantiation for funding decisions. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 15 
Adding Manpower in Field Offices With Two or Fewer 

Inspectors 

The STSIP needs more inspectors at most of its field offices to 

ensure that work continues when one inspector is unavailable. Of 

the 54 TSI field offices, 30 have only two inspectors and 4 field 

offices have only one. When inspectors are in training or on leave, 

often field offices will have one or no inspectors. In 2007, 12.7% 

of inspectors’ time was dedicated to training and at least 5% of 

inspector’s time was reserved for personal leave. 

According to STSIP performance reports, most field inspection 

time is dedicated to activities that require at least two experienced 

TSIs. For safety purposes, SAI reviews and other site visits to 

freight rail facilities require the participation of at least two TSIs 

who are sufficiently experienced in the freight rail mode. 

Additionally, BASE assessments require the participation of at 

least two TSIs who are familiar with the mass transit environment 

to ensure assessment accuracy. When one TSI is unavailable, most 

field offices are incapable of performing routine duties without 

borrowing inspectors from other field offices. 

Enforcing pending regulations also will involve site visits to 

freight rail facilities, which for safety purposes require two 

experienced TSIs. Pending regulations will require rail hazardous 

materials facilities within High Threat Urban Areas to apply an 

enhanced chain of custody and control measures when receiving or 

unloading hazardous materials. Experienced TSIs will need to 

visit these facilities to inspect and test compliance with this 

regulation. 

Recommendations 

We recommend that the Administrator of the Transportation 

Security Administration: 

Recommendation #2: Examine how many inspectors are needed 

to perform necessary functions by assessing current and anticipated 

future duties, and then expand the TSI workforce to ensure that 

each field office has sufficient staffing. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

Page 16 
Management Comments and OIG Analysis 

TSA’s Comments to Recommendation #2: 

TSA concurred with the recommendation. TSA stated it has 

implemented an approach to maximize national coverage by TSIs. 

TSA stated that a minimum of two inspectors per office ensures 

the capability to meet security assessment, inspection, and support 

demands while maintaining operational safety. TSA noted that 

when one inspector is absent, a TSI from another office can fill the 

need. Additionally, TSA stated it has cross-trained 200 aviation 

and cargo inspectors to assist surface inspectors. 

OIG Analysis: TSA faces an important and difficult challenge 

fulfilling the requirements of the 9/11 Commission Act and 

increased expectations of its TSI workforce. TSA’s FY 2010 

STSIP budget request identifies numerous activities and 

responsibilities, such as inspection and assessment, that TSIs will 

be obligated to perform in the near future. 

We do not dispute that TSA is using, and will continue to use, a 

risk-based approach to allocate its TSI resources. We are more 

concerned that the STSIP is insufficiently staffed to meet current 

workload demands. At TSA’s request, we changed the wording of 

our recommendation from “determine” to “examine,” but simply 

stated that TSA should be planning with more precision how many 

inspectors it will need. 

An issue that may warrant further examination is the STSIP’s 

ability to adapt to situations when it must backfill a TSI locally. It 

is only one example among several that formed the basis for our 

recommendation. Although we did not assess the skills and 

abilities of non-surface inspectors cross-trained for such situations, 

AFSDs–Surface are reporting that aviation and cargo inspectors 

are incapable of performing most surface inspector duties and that 

it would be unsafe for them to substitute for surface inspectors in a 

freight rail environment. As a result, we believe that STSIP 

operations are still vulnerable in these situations. Furthermore, 

FSDs have exacerbated this problem by hiring surface inspectors 

without mass transit or freight rail experience. TSA claims that 

two TSIs are needed per office to maintain operational safety, yet 

four field offices have only one inspector. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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We acknowledge that TSA may be waiting for regulations to take 

effect before increasing its current workforce. Accordingly, in its 

action plan, TSA should describe the steps it is taking to assess the 

number of inspectors needed to perform both current and future 

functions. 

This recommendation is Unresolved – Open. 

Command Structure Inhibits Surface Inspector Effectiveness 

The current TSI command structure inhibits TSI effectiveness. In 

December 2006, TSA shifted from a system where TSIs reported to 

surface-focused supervisors to a system where TSIs report to aviationfocused supervisors. As a result, TSIs who do not have appropriate 

surface experience have been hired, and TSIs have been tasked with nonsurface related tasks. These actions are affecting the quality and morale of 

the work force. 

The Transportation Surface Inspector Command Structure 

Although TSA’s Operation Directives 400-54-3 prescribes a single 

chain of command, to surface inspectors their chain of command is 

much less clear due to the current organizational structure and 

nature of communication between headquarters and field 

personnel. The STSIP office at TSA headquarters determines the 

mission and tasks of surface inspectors, but the inspectors 

ultimately report to an FSD in a nearby airport. The FSD is the 

senior TSA official at an airport and is responsible for providing 

operational leadership for transportation security responsibilities. 

Pursuant to TSA’s Delegation of Authority 400.1, the FSD is also 

responsible for assessing threats to transportation systems and 

enforcing regulations within his or her area of responsibility. 

Where an FSD’s area of responsibility is expanded outside of the 

airport, the FSD has responsibility over other surface modes. 

TSA has made two major revisions to the program’s organizational 

structure. Originally, TSIs in the field reported to a supervisory 

TSI, who reported directly to the STSIP office at TSA 

headquarters (see figure 9). 

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Figure 9. Original TSI Command Structure 

In December 2006, TSA reorganized the program to match the field 

command model for aviation and cargo inspectors. Supervisory 

TSIs became AFSDs–Surface who report to the local FSD. The 

FSD is the administrative manager, but the STSIP headquarters 

office still sets the priorities and provides the budget resources for 

the inspectors in the field. AFSDs–Surface, therefore, effectively 

have two chains of command. 

In May 2008, TSA made further changes. In primary field offices 

that have an AFSD–Surface, TSIs report to that individual. In 

satellite field offices without an AFSD–Surface, inspectors report 

to the local Assistant Federal Security Director – Inspections 

(AFSD–Inspections). However, the AFSD–Surface at the nearby 

primary field office still mentors and advises all surface inspectors 

within that area, even when they are not under his or her direct 

command. Under this structure, 55 (37%) of TSIs report to an 

AFSD–Surface, and the remaining 95 (63%) report to an aviationfocused AFSD–Inspections (see figure 10). 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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Figure 10. Current TSI Command Structure 

FSD Involvement in STSIP 

We observed several problems regarding FSDs’ involvement with 

the STSIP that have led to tension and confusion over the 

program’s chain of command. At the TSA Administrator’s 

direction, FSDs are responsible for the security of all transportation 

modes in their assigned region. However, the FSD position is 

primarily focused on aviation security, which limits FSDs’ ability 

to engage the surface modes. TSA officials agreed that FSDs have 

historically focused most of their attention on the security of their 

airports. According to officials, this is most prevalent in cities 

with major airports, where the FSD’s aviation duties consume 

more time. These major airports also tend to be located in cities 

with major mass transit systems or freight rail operations. The 

surface mode is a second-tier priority for many FSDs, and the FSD 

position description does not mention surface responsibilities. 

Second, FSDs generally lack a surface transportation background. 

TSA has taken steps to educate FSDs on the surface modes, such 

as requiring that they attend the Transportation Technology Center 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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Inc. in Pueblo, Colorado, to familiarize themselves with rail 

operations. One of TSA’s justifications for the initial realignment 

of the STSIP was that it would “enhance the domain awareness 

capabilities of FSDs in all surface transportation modes.” 

However, according to most AFSDs–Surface, this has not occurred 

to any great extent. Many AFSDs–Surface said that their FSD is 

not heavily engaged in surface transportation security, deferring to 

the AFDs–Surface subject matter expertise and allowing TSIs to 

operate without interference. 

Third, FSDs have not always shown the same deference when 

hiring TSIs. FSDs have hired people who do not have surface 

experience for senior TSI positions. Following the reorganization 

in December 2006, the local FSD assumed hiring authority for all 

new TSI personnel. Since that time, FSDs have hired 18 surface 

inspectors. In some cases, the AFSD–Surface was involved in the 

hiring process, but several said that the FSD did not include them. 

Several also said that the FSD hired someone other than the first 

choice of the AFSD–Surface. These new hires had not worked in a 

rail or mass transit environment. Of the 18 inspectors hired, 5 

were entry-level positions. Of the remaining 13 positions, FSDs 

filled 9 (69%) of the positions with individuals with no rail or mass 

transit experience (see figure 11). 

Of the nine individuals hired with inadequate surface experience, 

four were Transportation Security Inspectors – Aviation, two were 

Security Instructors, two were Transportation Security Officers 

(screeners), and one was a hazmat truck driver. With the exception 

of the truck driver, these hires were reassigned to their new 

positions without open competition. In one case, a D-band 

screener who had been with TSA for less than 4 months was 

reassigned to an H-Band TSI position, receiving a raise of more 

than $27,000. The hazmat truck driver was hired to an I-Band 

position after completing a knowledge, skills, and ability 

assessment with incorrect information. 

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Figure 11. TSI Hires, December 2006–July 2008 

I Band 

Annual salary: 

$67,707 - $86,857 

plus locality 

adjustment 

H Band 

Annual salary: 

$45,965 - $71,225 

plus locality 

adjustment 

G Band 

(Entry Level) 

Annual salary: 

$37,683 - $58,388 

plus locality 

adjustment 

Competitive Hires Non-Competitive Hires 

Hire With Previous Rail or Mass Hire With No Previous Rail
 

Transit Experience or Mass Transit Experience
 

The TSI program benefits when new hires have prior surface 

transportation experience. Rail yards are inherently dangerous 

places, with a number of safety considerations. TSIs told us that 

even the extensive training they receive cannot supplant years of 

safety-conscious experience. One AFSD–Surface said that he did 

not feel comfortable with his new TSIs entering the rail yard 

without an experienced TSI present. Also, TSIs who bring an 

existing network of contacts within the surface transportation mode 

will be much more effective as a liaison. While TSA has 

successfully hired junior TSIs without previous surface experience, 

both AFSD–Surface and TSA headquarters personnel expressed 

concerns about senior TSIs coming aboard without appropriate 

experience in rail. Congress echoed these concerns in the 9/11 

Commission Act, which states that “surface transportation security 

inspectors [are required to] have relevant transportation experience 

and other security and inspection qualifications.”3 

Fourth, FSDs have tasked TSIs with non-surface-related tasks. In 

several cities, FSDs have tasked TSIs with airport assignments, 

such as handing out plastic bags at the security checkpoints or 

monitoring the checkpoint exit lane. While FSDs have the 

authority to reassign all of their assets during periods of heightened 

alert or increased threat, there is no indication that these taskings 

3

 Public Law 110-53 section 1304(d) 

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took place during such a time. Rather, most of the non-surfacerelated tasks seemed to have stemmed from manpower issues at the 

airport. TSIs reported that these activities lowered morale, 

affected their relationship with their FSD, and ultimately served as 

a poor use of their expertise. These activities also illustrate the 

airport focus of the FSD. 

STSIP headquarters officials informally communicate priorities to 

the AFSD–Surface, with little notification or engagement on the 

part of FSDs. A majority of TSIs are not actually reporting to their 

current supervisor, the AFSD–Inspections, but instead look to their 

previous supervisor, an AFSD–Surface, for direction. As one 

AFSD–Surface said, “The only thing [the AFSD–Inspections] is 

doing now is signing their timecards.” 

Although TSIs are able to complete assigned tasks while officially 

reporting to the FSDs, the structural, morale, and hiring problems 

that we observed are detrimental to the STSIP. Only 4% of TSIs 

and only 1 of the 11 AFSDs–Surface preferred to retain the current 

chain of command. Despite TSIs’ concerns about their chain of 

command and management of the program, TSA headquarters 

officials said that the existing system is adequate. 

Recommendations 

We recommend that the Administrator of the Transportation 

Security Administration: 

Recommendation #3 (revised): Eliminate practices that 

undermine efforts to establish a more transparent chain of 

command. Instruct the STSIP office to direct new policies and 

actions to FSDs for implementation and require FSDs to solicit 

comments from AFSDs prior to hiring surface inspectors. 

Management Comments and OIG Analysis 

TSA’s Comments to Recommendation #3: 

TSA did not concur with our original recommendation to place the 

Transportation Security Inspectors–Surface under the direct 

authority of a TSA headquarters official who is responsible for 

surface transportation, such as the Office of Security Operations’ 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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Assistant General Manager for Compliance. TSA stated that it has 

chosen its command structure because FSDs are better able to use 

the security network in the area. TSA noted that FSDs frequently 

interact with state and local law enforcement and mass transit 

operators. TSA believes that FSDs understand the vulnerabilities 

and challenges of the mass transit modes “in their backyard.” 

TSA stated that the OIG relied largely on data collected during a 

prior audit. TSA believes that its reporting lines are clear and are 

described in Operational Directive 400-54-3. The STSIP informs 

FSDs of TSI priorities via written directives and communications 

distributed electronically through the Office of Security 

Operations’ Leveraging Information, Networks, and 

Communication system. The STSIP also provides FSDs with 

weekly written reports on key activities. AFSDs–Surface 

participate in a weekly national conference call hosted by the 

STSIP, and AFSDs and local lead TSIs are required to attend FSD 

meetings and routinely report STSIP activities to FSDs. 

OIG Analysis: This review was distinct from our inspection and 

report, Transportation Security Administration’s Administration 

and Coordination of Mass Transit Security Programs. That review 

covered June to October 2007. The period for this review was 

February to July 2008 and consisted of completely new interviews 

and site visits. We referenced one statement from the previous 

review—only 4% of TSIs preferred to retain the current chain of 

command. 

Our June 2008 report, “TSA’s Administration and Coordination of 

Mass Transit Security Programs,” recommended that TSA should 

return the TSIs to the direct authority of a TSA headquarters 

official who is responsible for surface transportation. TSA did not 

concur with the recommendation, which was unresolved at the start 

of this review. We reexamined the issue during this review and 

again recommended in our draft report that TSA return the TSIs to 

the direct authority of a headquarters official who is responsible for 

surface transportation. Despite our new analysis and updated 

reporting of this issue, TSA reiterated its position that the present 

TSI command structure does not inhibit TSI effectiveness. 

The STSIP chain of command still operates differently than 

described in Operational Directive 400-54-3. For example, the 

directive does not mention the program’s weekly national 

conference call, yet this is an essential part of the TSI command 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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structure. AFSDs–Surface and local lead TSIs are tasked directly 

from the STSIP through the weekly national call and by the FSDs. 

TSA acknowledged that AFSDs–Surface participate in the STSIP 

office’s conference call and must inform FSDs within their 

respective regions of new or changing processes in STSIP 

programs. The confluence of communication occurring between 

headquarters and field personnel during such calls speaks to the 

very heart of the issue. 

We also reported several problems regarding FSDs involvement 

with the STSIP that have led to tension and confusion regarding 

the program’s chain of command. The FSD position is primarily 

focused on aviation security, and FSDs generally have minimal 

surface transportation background, both of which limit FSDs’ 

ability to engage the surface modes. In addition, FSDs have hired 

people for senior TSI positions who do not have surface experience 

and have tasked TSIs with non-surface-related tasks. 

We again sought to convince TSA to place TSIs under the direct 

authority of a TSA headquarters official responsible for surface 

transportation. However, in the absence of a commitment from 

TSA management to modify its command structure, we have 

retracted our original recommendation and instead are 

recommending that TSA eliminate practices that undermine efforts 

to establish a more transparent chain of command. In both the exit 

conference and its response, TSA signaled that it is trying to 

strengthen communication between headquarters and TSIs. In its 

action plan, TSA should describe how it is improving FSD 

involvement in the STSIP. 

This recommendation is Resolved – Open. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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Appendix A 

Purpose, Scope, and Methodology 

As directed by the 9/11 Commission Act, we evaluated the performance 

and effectiveness of TSA’s Transportation Security Inspectors–Surface 

and whether there is a need for additional inspectors. The act states: 

“Not later than September 30, 2008, the Department of Homeland 

Security Inspector General shall transmit a report to the appropriate 

congressional committees on the performance and effectiveness of 

surface transportation security inspectors, whether there is a need for 

additional inspectors, and other recommendations.” 

We conducted our fieldwork from February to July 2008. We interviewed 

representatives from TSA’s Office of Transportation Sector Network 

Management, Office of Law Enforcement, Office of Field Operations, and 

Transportation Security Operations Center. We spoke with all 11 AFSD– 

Surface, 6 FSDs, 2 AFSD–Inspections, and several TSIs. We also spoke 

with officials and inspectors from the U.S. Coast Guard and the 

Department of Transportation’s Federal Railroad Administration, Federal 

Transit Administration, Pipeline and Hazardous Material Safety 

Administration, and Federal Motor Carrier Safety Administration. 

In addition to testimonial evidence from interviews, we examined: 

�	 Laws, regulations and security directives relevant to surface 

transportation, and federal authorities and responsibilities; 

�	 

�	 

�	 

�	 

�	 

Memorandums and directives documenting reorganizations and 

personnel changes within TSA; 

Documentation on the VIPR program; 

Sample BASE reviews, SAI reviews, and station profiles; 

Sample weekly status reports and monthly performance reports on the 

activities of TSIs; and 

TSI personnel files. 

We also observed: 

�	 

�	 

�	 

TSIs conducting a BASE review; 

TSIs conducting an SAI review; and 

TSIs participating in a VIPR exercise. 

This review was conducted under the authority of the Inspector General 

Act of 1978, as amended, and according to the Quality Standards for 

Inspections, issued by the President’s Council of Integrity and Efficiency. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix C 

Freight Rail Security Action Items 

Department of Homeland Security and the Department of Transportation Freight 

Rail Security Action Items 

System Security Practices Affecting the Transportation of TIH Materials 

1. Designate an individual with overall responsibility for hazardous materials transportation security 

planning, training, and implementation. This individual should report directly to an executive officer of the 

company. Designate an individual with overall responsibility for security planning and countermeasure 

implementation for company-designated critical infrastructure. 

2. Conduct exercises, at least annually, to verify the effectiveness of security plan(s). 

3. Develop and conduct an internal or external company audit program to independently verify that the 

security plan is being implemented effectively. The audit process should include a policy for record 

keeping of the audit and a method for management review and performance measurement. 

4. Identify and then annually review company-designated critical infrastructure. Ensure that changes or 

additions to the operating environment have been properly addressed. 

5. Maintain a communications network to receive timely government notices of current threat conditions 

and available intelligence information. Adjust security measures as necessary to reflect current threats and 

vulnerabilities based on available information. 

6. Make use of opportunities to establish liaison and regular communication with federal, state, and local 

law enforcement, emergency responders, security agencies, and industry partners. Strive to make local law 

enforcement aware of railroad security issues. 

7. Establish liaison and collaboration with other railroad security offices to promote information sharing 

and security enhancements. 

8. As with industry safety programs, regularly reinforce security awareness and operational security 

concepts to all employees at all levels of the organization. 

9. Reinforce the need for employees to immediately report to the proper authorities all suspicious persons, 

activities, or objects encountered. 

10. Have contingency plans in place to supplement company security personnel to protect companydesignated critical infrastructure as threat conditions warrant, such as contracts to engage private security 

guard providers or procedures to request supplemental physical security assistance of federal, state, local, 

and tribal authorities. 

11. Restrict access to information controlled by the railroad that it determines to be sensitive, in particular 

information about hazardous materials shipments and security measures. 

12. Make available emergency response planning materials and, when requested, work with local 

communities to facilitate their training and preparation to deploy and respond to an emergency or security 

incident. 

13. Cooperatively work with federal, state, local, and tribal governments to identify, through risk 

assessments, the locations where security risks are highest. Cooperatively work with federal, state, local, 

and tribal governments to identify and implement protective measures at these locations. 

Access Control Security Practices 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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Appendix C 

Freight Rail Security Action Items 

14. Focus proactive community safety and security outreach and trespasser abatement programs in areas 

adjacent to company-designated critical infrastructure to reduce the likelihood of unauthorized individuals 

on company property and to enhance public awareness of the importance of reporting suspicious activity. 

15. To the extent feasible and practicable, use photo identification procedures for company-designated 

critical infrastructure. Establish procedures for background checks and safety and security training for 

contractor employees with unmonitored access to company-designated critical infrastructure. 

16. To the extent feasible and practicable, and as threat conditions warrant, restrict the access of contractors 

and visitors at nonpublic areas of company-designated critical infrastructure, and monitor the activities of 

visitors in or around such infrastructure. 

17. Establish employee identification measures for all employees. Conduct spot checks of identification as 

threat conditions warrant. 

18. Implement measures to deter unauthorized entry and increase the probability of detection at companydesignated critical infrastructure as threat conditions warrant. To the extent that patrols are used, vary the 

pattern and schedule to avoid predictability. 

19. Use interlocking signals and/or operating rules to prevent trains from occupying moveable bridges until 

the bridges are locked in place. 

En-Route Security Practices 

20. Maintain systems to locate rail cars transporting TIH materials in a timely manner to implement 

security measures when necessary and provide information on the location of rail cars carrying TIH 

materials to Department of Homeland Security (DHS) and Department of Transportation (DOT), as 

requested, in case of events of national significance. 

21. During required on-ground safety inspections of cars containing TIH materials, inspect for any apparent 

signs of tampering, sabotage, attached explosives, and other suggested items. Train employees to 

recognize suspicious activity and report security concerns found during inspections. 

22. Provide local authorities with information on the hazardous materials transported through their 

communities consistent with Association of American Railroads (AAR) Circular OT-55. 

23. Consider alternative routes when they are economically practicable and result in reduced overall safety 

and security risks. Work with the DHS and DOT in developing better software tools to analyze routes. 

24. In rail yards, to the extent feasible, place cars containing TIH materials where the most practical 

protection can be provided against tampering and outside interference when appropriate for the threat level 

in the geographic area, in accordance with the AAR Security Management Plan. 

Supplemental Security Action Item No. 1 

Rail carriers with operations in High Threat Urban Areas (HTUA) will develop site-specific security plans 

that address the security of the transportation in bulk of TIH material in loaded rail cars (“TIH cars”) in 

HTUA. The site-specific security plan should include specific and detailed measures to enhance the 

security of TIH cars in the carrier’s custody. These plans should be completed within 90 days of the 

issuance date of the guidelines. 

Effectiveness of TSA’s Surface Transportation Security Inspectors 

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Appendix C 

Freight Rail Security Action Items 

The site-security plan will address the following objectives for railroad operations within HTUA: 

1. Reduce the number of hours that TIH cars are held in yards, terminals, and on railroad-controlled leased 

track in HTUA. 

2. Minimize the occurrence of unattended TIH cars in HTUA. 

3. Reduce potential exposure to surrounding people, property and environment in HTUA. Special 

emphasis should be placed on reducing potential exposure to hospitals, high-occupancy buildings, schools, 

and public venues. 

4. Reduce the occurrence of standing TIH trains in HTUA. 

5. Provide a procedure for the protection or surveillance of unattended TIH trains in HTUA 

6. Ensure compliance with CFR 49 Part 174.14 (48-hour rule). 

7. Develop site-specific procedures for the positive and secure handoff of TIH cars at points of origin, 

destination, and interchange in HTUA. 

Supplemental Security Action Item No. 2 

Rail carriers will not operate trains carrying TIH within a specified distance of public venues with National 

Special Security Events in progress and as requested by the appropriate agency responsible for overall 

event security coordination. 

Supplemental Security Action Item No. 3 

Rail carriers will, in the security planning process, identify and select areas throughout the carrier’s system 

where cars containing TIH can be moved and held when threat conditions warrant. Risk and exposure to 

the general public are factors to be considered in the selection process. The rail carrier will provide this 

information to the government upon request. 

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Appendix D 

Major Contributors to this Report 

William McCarron, Chief Inspector, Department of Homeland 

Security, Office of Inspections 

Preston Jacobs, Inspector, Department of Homeland Security, 

Office of Inspections 

Tristan Weir, Inspector, Department of Homeland Security, 

Office of Inspections 

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Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Administrator, Transportation Security Administration 

TSA Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

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ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4199, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.