Persistence Analytics Group LLC - Comments

To the Transportation Security Administration — Re: Docket No. TSA-2003-14610 — Security Threat Assessment for Individuals Applying for a Hazardous Materials Endorsement for a Commercial Driver’s License Persistence Analytics Group LLC respectfully submits this comment regarding TSA’s Information Collection Request for Security Threat Assessments for individuals applying for a Hazardous Materials Endorsement on a Commercial Driver’s License. PAG is a national security and infrastructure risk analytics firm focused on implementation-assumption verification, decision assurance, identity-system integrity, critical-infrastructure risk, and public-trust exposure. This collection should not be viewed only as a Paperwork Reduction Act burden issue. It is part of the nation’s transportation-security and hazardous-materials identity-verification infrastructure. Drivers with HazMat endorsements operate inside a high-consequence risk environment involving hazardous materials, freight corridors, ports, logistics networks, industrial facilities, energy infrastructure, emergency response, and public safety. The core question is: What must be verified before TSA, states, employers, and the public rely on an identity and threat-assessment system for hazardous-materials access? PAG respectfully recommends that TSA evaluate the collection through an implementation-verification framework addressing: 1. Identity Accuracy What evidence confirms that biographic and biometric identity matching reliably identifies the applicant and minimizes false positives, false negatives, duplicate records, and misidentification? 2. Data Integrity Across Jurisdictions Because states, TSA enrollment providers, TWIC systems, FBI systems, and CDL records may interact, what controls verify that applicant records remain accurate, current, and auditable? 3. Security Threat Assessment Reliability What assumptions underlie TSA’s determination that an applicant is or is not a transportation-security threat, and how are those assumptions tested over time? 4. Recurrent Vetting and Rap Back Governance What standards govern recurrent criminal-history vetting through FBI Rap Back, and how does TSA ensure timely, accurate, and fair handling of post-issuance disqualifying information? 5. Appeal and Waiver Burden What practical burden falls on applicants who are initially deemed ineligible, require correction, or must pursue an appeal or waiver within the required timeframe? 6. TWIC / HME / TSA PreCheck Comparability What evidence supports comparability determinations across TWIC, HME, and TSA PreCheck eligibility, and how does TSA prevent errors when credentials are reused across programs? 7. Online Renewal Cybersecurity As TSA expands online renewal and re-enrollment, what cybersecurity, authentication, fraud-prevention, vendor, and data-retention assumptions must hold? 8. Public-Safety Consequence of Failure If the system fails, who bears the downside: the driver, employer, state licensing agency, TSA, carrier, shipper, port, industrial facility, emergency responder, or public? PAG is not opposing the HME Security Threat Assessment program. The issue is that programs of this type become national-security infrastructure when they determine who is trusted to transport hazardous materials. That means the implementation assumptions must be verified before the public relies on them. A HazMat credential is only as strong as the verification layer underneath it. Trust the credential. Verify the system. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/ SAM.gov Registered Vendor UEI: D3VYU39H6DX9 | CAGE: 19T34 D-U-N-S: 142849930