Transportation Worker Identification Credential: Card Reader Pilot Results Are Unreliable; Security Benefits Should Be Reassessed
Published: 2013-06-18T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: This testimony discusses GAO's recent work examining the Department of Homeland Security's (DHS) Transportation Worker Identification Credential (TWIC) program. Ports, waterways, and vessels handle billions of dollars in cargo annually, and an attack on our nation's maritime transportation system could have serious consequences. Maritime workers, including longshoremen, mechanics, truck drivers, and merchant mariners, access secure areas of the nation's estimated 16,400 maritime-related transportation facilities and vessels, such as cargo container and cruise ship terminals, each day while performing their jobs.
section_title: What GAO Found
paragraphs: This statement today highlights the key findings of GAO's May 8, 2013, report on the TWIC program, which addressed the extent to which the results from the TWIC reader pilot were sufficiently complete, accurate, and reliable for informing Congress and the TWIC card reader rule.

section_title: Letter
paragraphs: I am pleased to be here today to discuss our work examining the  Department of Homeland Security’s (DHS) Transportation Worker  Identification Credential (TWIC) program. Ports, waterways, and vessels  handle billions of dollars in cargo annually, and an attack on our nation’s  maritime transportation system could have serious consequences.  Maritime workers, including longshoremen, mechanics, truck drivers, and  merchant mariners, access secure areas of the nation’s estimated 16,400  maritime-related transportation facilities and vessels, such as cargo  container and cruise ship terminals, each day while performing their jobs.
The TWIC program is intended to provide a tamper-resistant biometric  credential to maritime workers who require unescorted access to secure  areas of facilities and vessels regulated under the Maritime  Transportation Security Act of 2002 (MTSA). TWIC is to enhance the  ability of MTSA-regulated facility and vessel owners and operators to  control access to their facilities and verify workers’ identities. Under  current statute and regulation, maritime workers requiring unescorted  access to secure areas of MTSA-regulated facilities or vessels are  required to obtain a TWIC, and facility and vessel operators are required  by regulation to visually inspect each worker’s TWIC before granting  unescorted access. Prior to being granted a TWIC, maritime workers are  required to undergo a background check, known as a security threat  assessment.
Within DHS, the Transportation Security Administration (TSA) and the  U.S. Coast Guard (USCG) jointly administer the TWIC program. USCG is  leading efforts to develop a new TWIC regulation (rule) regarding the use  of TWIC cards with readers (known as the TWIC card reader rule). The  TWIC card reader rule is expected to define if and under what  circumstances facility and vessel owners and operators are to use  electronic card readers to verify that a TWIC card is valid. USCG  published the TWIC card reader notice of proposed rulemaking (NPRM)  on March 22, 2013, and has since extended the public comment period to  June 20, 2013.
To help inform this rulemaking and to fulfill the Security and Accountability  For Every Port Act of 2006 (SAFE Port Act) requirement, TSA conducted  a TWIC reader pilot from August 2008 through May 2011 to test a variety  of biometric readers, as well as the credential authentication and  validation process. The TWIC reader pilot, implemented with the  voluntary participation of maritime port, facility, and vessel operators, was  to test the technology, business processes, and operational impacts of  deploying card readers at maritime facilities and vessels prior to issuing a  final rule. Among other things, the SAFE Port Act required that DHS  submit a report on the findings of the pilot program to Congress. DHS  submitted its report to Congress on the findings of the TWIC reader pilot  on February 27, 2012. The Coast Guard Authorization Act of 2010  required that, among other things, GAO conduct an assessment of the  report’s findings and recommendations.
We have been reporting on TWIC progress and challenges since  September 2003. Among other issues, we highlighted steps that TSA  and USCG were taking to meet an expected surge in initial enrollment as  well as various challenges experienced in the TWIC testing conducted by  a contractor for TSA and USCG from August 2004 through June 2005.  We also identified challenges related to ensuring that the TWIC  technology works effectively in the harsh maritime environment. In  November 2009, we reported on the design and approach of a pilot  initiated in August 2008 to test TWIC readers, and found that DHS did not  have a sound evaluation methodology to ensure information collected  through the TWIC reader pilot would be complete and accurate.  Moreover, in May 2011, we reported that internal control weaknesses  governing the enrollment, background checking, and use of TWIC  potentially limit the program’s ability to provide reasonable assurance that  access to secure areas of MTSA-regulated facilities is restricted to  qualified individuals.
My statement today highlights the key findings of our May 8, 2013, report  on the TWIC program, which addressed the extent to which the results  from the TWIC reader pilot were sufficiently complete, accurate, and  reliable for informing Congress and the TWIC card reader rule. For the  report, among other things, we assessed the methods used to collect and  analyze pilot data since the inception of the pilot in August 2008. We  analyzed and compared the pilot data with the TWIC reader pilot report  submitted to Congress to determine whether the findings in the report are  based on sufficiently complete, accurate, and reliable data. Additionally,  we interviewed officials at DHS, TSA, and USCG with responsibilities for  overseeing the TWIC program, as well as pilot officials responsible for  coordinating pilot efforts with TSA and the independent test agent  (responsible for planning, evaluating, and reporting on all test events),  about TWIC reader pilot testing approaches, results, and challenges. Our  investigators also conducted limited covert testing of TWIC program  internal controls for acquiring and using TWIC cards at four maritime  ports to update our understanding of the effectiveness of TWIC at  enhancing maritime security since we reported on these issues in May  2011. Our May 2013 report includes additional details on our scope and  methodology. We conducted this work in accordance with generally  accepted government auditing standards, and conducted the related  investigative work in accordance with standards prescribed by the Council  of the Inspectors General on Integrity and Efficiency.
subsections: section_title: TWIC Reader Pilot Results Are Not Sufficiently Complete, Accurate, and Reliable for Informing Congress and the TWIC Card Reader Rule
paragraphs: Our review of the pilot test identified several challenges related to pilot  planning, data collection, and reporting, which affected the completeness,  accuracy, and reliability of the results.
subsections: section_title: Pilot Planning
paragraphs: DHS did not correct planning shortfalls that we identified in our November  2009 report. We determined that these weaknesses presented a  challenge in ensuring that the pilot would yield information needed to  inform Congress and the card reader rule and recommended that DHS  components implementing the pilot—TSA and USCG—develop an  evaluation plan to guide the remainder of the pilot and identify how it  would compensate for areas where the TWIC reader pilot would not  provide the information needed. DHS agreed with the recommendations;  however, while TSA developed a data analysis plan, TSA and USCG  reported that they did not develop an evaluation plan with an evaluation  methodology or performance standards, as we recommended. The data  analysis plan was a positive step because it identified specific data  elements to be captured from the pilot for comparison across pilot sites. If  accurate data had been collected, adherence to the data analysis plan  could have helped yield valid results. However, TSA and the independent  test agent did not utilize the data analysis plan. According to officials  from the independent test agent, they started to use the data analysis  plan but stopped using the plan because they were experiencing difficulty  in collecting the required data and TSA directed them to change the  reporting approach. TSA officials stated that they directed the  independent test agent to change its collection and reporting approach  because of TSA’s inability to require or control data collection to the  extent required to execute the plan.
section_title: Data Collection
paragraphs: We identified eight areas where TWIC reader pilot data collection,  supporting documentation, and recording weaknesses affected the  completeness, accuracy, and reliability of the pilot data.  1.  Installed TWIC readers and access control systems could not  collect required data on TWIC reader use, and TSA and the  independent test agent did not employ effective compensating  data collection measures. The TWIC reader pilot test and evaluation  master plan recognizes that in some cases, readers or related access  control systems at pilot sites may not collect the required test data,  potentially requiring additional resources, such as on-site personnel,  to monitor and log TWIC card reader use issues. Moreover, such  instances were to be addressed as part of the test planning. However,  the independent test agent reported challenges in sufficiently  documenting reader and system errors. For example, the independent  test agent reported that the logs from the TWIC readers and related  access control systems were not detailed enough to determine the  reason for errors, such as biometric match failure, an expired TWIC  card, or that the TWIC was identified as being on the list of revoked  credentials. The independent test agent further reported that the  inability to determine the reason for errors limited its ability to  understand why readers were failing, and thus it was unable to  determine whether errors encountered were due to TWIC cards,  readers, or users, or some combination thereof.  2.  Reported transaction data did not match underlying  documentation. A total of 34 pilot site reports were issued by the  independent test agent. According to TSA, the pilot site reports were  used as the basis for DHS’s report to Congress. We separately  requested copies of the 34 pilot site reports from both TSA and the  independent test agent. In comparing the reports provided, we found  that 31 of the 34 pilot site reports provided to us by TSA did not  contain the same information as those provided by the independent  test agent. Differences for 27 of the 31 pilot site reports pertained to  how pilot site data were characterized, such as the baseline  throughput time used to compare against throughput times observed  during two phases of testing. However, at two pilot sites, Brownsville  and Staten Island Ferry, transaction data reported by the independent  test agent did not match the data included in TSA’s reports. Moreover,  data in the pilot site reports did not always match data collected by the  independent test agent during the pilot.  3.  Pilot documentation did not contain complete TWIC reader and  access control system characteristics. Pilot documentation did not  always identify which TWIC readers or which interface (e.g., contact  or contactless interface) the reader used to communicate with the  TWIC card during data collection. For example, at one pilot site, two  different readers were tested. However, the pilot site report did not  identify which data were collected using which reader.  4.  TSA and the independent test agent did not record clear baseline  data for comparing operational performance at access points  with TWIC readers. Baseline data, which were to be collected prior to  piloting the use of TWIC with readers, were to be a measure of  throughput time, that is, the time required to inspect a TWIC card and  complete access-related processes prior to granting entry. However, it  is unclear from the documentation whether acquired data were  sufficient to reliably identify throughput times at truck, other vehicle,  and pedestrian access points, which may vary.  5.  TSA and the independent test agent did not collect complete  data on malfunctioning TWIC cards. TSA officials observed  malfunctioning TWIC cards during the pilot, largely because of broken  antennas. If a TWIC with a broken antenna was presented for a  contactless read, the reader would not identify that a TWIC had been  presented, as the broken antenna would not communicate TWIC  information to a contactless reader. In such instances, the reader  would not log that an access attempt had been made and failed.  6.  Pilot participants did not document instances of denied access.
Incomplete data resulted from challenges documenting how to  manage individuals with a denied TWIC across pilot sites. Specifically,  TSA and the independent test agent did not require pilot participants  to document when individuals were granted access based on a visual  inspection of the TWIC, or deny the individual access as may be  required under future regulation. This is contrary to the TWIC reader  pilot test and evaluation master plan, which calls for documenting the  number of entrants “rejected” with the TWIC card reader system  operational as part of assessing the economic impact. Without such  documentation, the pilot sites were not completely measuring the  operational impact of using TWIC with readers.  7.  TSA and the independent test agent did not collect consistent  data on the operational impact of using TWIC cards with readers.  TWIC reader pilot testing scenarios included having each individual  present his or her TWIC for verification; however, it is unclear whether  this actually occurred in practice. For example, at one pilot site,  officials noted that during testing, approximately 1 in 10 individuals  was required to have his or her TWIC checked while entering the  facility because of concerns about causing a traffic backup. Despite  noted deviations in test protocols, the reports for these pilot sites do  not note that these deviations occurred. Noting deviations in each pilot  site report would have provided important perspective by identifying  the limitations of the data collected at the pilot site and providing  context when comparing the pilot site data with data from other pilot  sites.  8.  Pilot site records did not contain complete information about  installed TWIC readers’ and access control systems’ design. TSA  and the independent test agent tested the TWIC readers at each pilot  site to ensure they worked before individuals began presenting their  TWIC cards to the readers during the pilot. However, the data  gathered during the testing were incomplete. For example, 10 of 15  sites tested readers for which no record of system design  characteristics were recorded. In addition, pilot reader information was  identified for 4 pilot sites but did not identify the specific readers or  associated software tested.
According to TSA, a variety of challenges prevented TSA and the  independent test agent from collecting pilot data in a complete and  consistent fashion. Among the challenges noted by TSA, (1) pilot  participation was voluntary, which allowed pilot sites to stop participation  at any time or not adhere to established testing and data collection  protocols; (2) the independent test agent did not correctly and completely  collect and record pilot data; (3) systems in place during the pilot did not  record all required data, including information on failed TWIC card reads  and the reasons for the failure; and (4) prior to pilot testing, officials did  not expect to confront problems with nonfunctioning TWIC cards.  Additionally, TSA noted that it lacked the authority to compel pilot sites to  collect data in a way that would have been in compliance with federal  standards. In addition to these challenges, the independent test agent  identified the lack of a database to track and analyze all pilot data in a  consistent manner as an additional challenge to data collection and  reporting. The independent test agent, however, noted that all data  collection plans and resulting data representation were ultimately  approved by TSA and USCG.
section_title: Reporting
paragraphs: As required by the SAFE Port Act and the Coast Guard Authorization Act  of 2010, DHS’s report to Congress on the TWIC reader pilot presented  several findings with respect to technical and operational aspects of  implementing TWIC technologies in the maritime environment. However,  DHS’s reported findings were not always supported by the pilot data, or  were based on incomplete or unreliable data, thus limiting the report’s  usefulness in informing Congress about the results of the TWIC reader  pilot. For example, reported entry times into facilities were not based on  data collected at pilot sites as intended. Further, the report concluded that  TWIC cards and readers provide a critical layer of port security, but data  were not collected to support this conclusion.
Because of the number of concerns that we identified with the TWIC pilot,  in our March 13, 2013, draft report to DHS, we recommended that DHS  not use the pilot data to inform the upcoming TWIC card reader rule.  However, after receiving the draft that we sent to DHS for comment, on  March 22, 2013, USCG published the TWIC card reader NPRM, which  included results from the TWIC card reader pilot. We subsequently  removed the recommendation from our final report, given that USCG had  moved forward with issuing the NPRM and had incorporated the pilot  results into the proposed rulemaking. In its official comments on our  report, DHS asserted that some of the perceived data anomalies we cited  were not significant to the conclusions TSA reached during the pilot and  that the pilot report was only one of multiple sources of information  available to USCG in drafting the TWIC reader NPRM. We recognize that  USCG had multiple sources of information available to it when drafting  the proposed rule; however, the pilot was used as an important basis for  informing the development of the NPRM, and the issues and concerns  that we identified remain valid.
Given that the results of the pilot are unreliable for informing the TWIC  card reader rule on the technology and operational impacts of using  TWIC cards with readers, we recommended that Congress consider  repealing the requirement that the Secretary of Homeland Security  promulgate final regulations that require the deployment of card readers  that are consistent with the findings of the pilot program, and that  Congress should consider requiring that the Secretary of Homeland  Security complete an assessment that evaluates the effectiveness of  using TWIC with readers for enhancing port security. This would be  consistent with the recommendation that we made in our May 2011  report. These results could then be used to promulgate a final regulation  as appropriate. Given DHS’s challenges in implementing TWIC over the  past decade, at a minimum, the assessment should include a  comprehensive comparison of alternative credentialing approaches,  which might include a more decentralized approach, for achieving TWIC  program goals.
Chairman Miller, Ranking Member Jackson-Lee, and members of the  subcommittee, this concludes my prepared statement. I would be happy  to respond to any questions that you may have.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For questions about this statement, please contact Steve Lord at (202)  512-4379 or lords@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. Individuals making key contributions to this statement  include Dave Bruno, Assistant Director; Joseph P. Cruz; and James  Lawson. Key contributors for the previous work that this testimony is  based on are listed within each individual product.
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