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Risk-Informed Analysis Of Transportation Worker Identification Credential Reader Requirements

The RAND Corporation published its long-awaited assessment of the Transportation Worker Identification Credential (TWIC) Reader Rule. The purpose of the assessment is to further consider the costs versus benefits of the TWIC Reader Rule, including the scope of affected facilities.

As an initial matter RAND has concluded:

• Between 471 and 711 Maritime Transportation Security Act–regulated facilities handle Certain Dangerous Cargo (CDC) in bulk and are therefore likely to be subject to the reader rule delay.
• Among the facilities observed to handle CDCs, anhydrous ammonia was the most common CDC, although many facilities handle more than one type of CDC.
• The consequence distribution of facilities that handle CDCs in bulk was highly skewed (i.e., many facilities with relatively low consequences and few facilities with extremely high consequences).
• The TWIC reader rule would have to avert a Transportation Security Incident (TSI) approximately every 60 to 90 years, at a minimum, to be cost-effective.
• Although the final reader rule is potentially cost-effective even in its current form, reasons exist to consider a more-targeted approach that excludes low-quantity or low–population density facilities, or both. Under hypothetical regulatory options, a more-targeted approach affecting only higher-consequence facilities would need to avert only one TSI approximately every 200 to 600 years to be cost-effective.
• The decision to use a wide net or a more-targeted approach could depend largely on policymakers’ preferences and relative risk tolerance considering trade-offs among several competing factors.