TSA Pipeline Operator Security Information Comments

Filed by
Dan Regan
Filed Date
09/28/2009
Recipients Agency
Ginger LeMay
Subject
TSA Information Collection Request
Docket ID:
TSA-2009-0015-0001
More On This
TSA Information Collection Request
20090928 INGAA Letter Comment (Final).pdf 33KB, PDF
09/28/2009
Download 33KB, PDF

On September 28, 2009, INGAA filed comments addressing the Transportation Security Administration’s proposal to solicit contact information and establish a voluntary incident reporting program as part of it forthcoming Pipeline Security Guidelines.  INGAA does not oppose TSA collecting contact information for pipeline security managers.  INGAA raises four objections to TSA’s incident reporting proposal:  (1) the proposal failed to address the potential civil liability associated with reporting “suspicious” activities that are later found to pose no threat to homeland security; (2) the proposed approach compromises the internal consistency of the reporting database by relying too heavily on subjective judgments about whether a particular activity is “suspicious;” (3) the proposed reporting of thefts of pipeline vehicles, uniforms and credentials runs counter to sound pipeline management policies, which involve local law enforcement when and as necessary, and threaten to flood pipelines and TSA with hundreds if not thousands of reports on events that pose no threat to homeland security; and (4) as part of developing an incident reporting program, TSA should coordinate with relevant federal, state and local authorities to establish a single point of contact and a single reporting form, so pipelines do not have to report the same event over and over to official after official.

LAST UPDATE
05/30/2011
Keywords
TSA Pipeline Security Information Incident reporting
Categories
DOT