Critical Infrastructure Protection: Actions Needed to Address Significant Weaknesses in TSA's Pipeline Security Program Management
Fast Facts
The nation depends on the interstate pipeline system to deliver oil, natural gas, and more. This increasingly computerized system is an attractive target for hackers and terrorists. (Protection of cyber critical infrastructure is on our High Risk List.)
We found weaknesses in how TSA manages its pipeline security efforts. For example, it has no process for determining when to update its guidelines for pipeline operators. Also, its method for assessing risks needs updating.
We made 10 recommendations, including establishing better processes for updating guidelines and assessing risks.
Map of Hazardous Liquid and Natural Gas Pipelines in the United States, September 2018
This map of the United States shows the massive network of pipelines.
Highlights
What GAO Found
Pipeline operators reported using a range of guidelines and standards to address physical and cybersecurity risks, including the Department of Homeland Security's (DHS) Transportation Security Administration's (TSA) Pipeline Security Guidelines, initially issued in 2011. TSA issued revised guidelines in March 2018 to reflect changes in the threat environment and incorporate most of the principles and practices from the National Institute of Standards and Technology's Framework for Improving Critical Infrastructure Cybersecurity. However, TSA's revisions do not include all elements of the current framework and TSA does not have a documented process for reviewing and revising its guidelines on a regular basis. Without such a documented process, TSA cannot ensure that its guidelines reflect the latest known standards and best practices for physical security and cybersecurity, or address the dynamic security threat environment that pipelines face. Further, GAO found that the guidelines lack clear definitions to ensure that pipeline operators identify their critical facilities. GAO's analysis showed that operators of at least 34 of the nation's top 100 critical pipeline systems (determined by volume of product transported) deemed highest risk had identified no critical facilities. This may be due, in part, to the guidelines not clearly defining the criteria to determine facilities' criticality.
U.S. Pipeline Systems' Basic Components and Vulnerabilities
To assess pipeline security risks, TSA conducts pipeline security reviews—Corporate Security Reviews and Critical Facility Security Reviews—to assess pipeline systems' vulnerabilities. However, GAO found that the number of TSA security reviews has varied considerably over the last several years, as shown in the table on the following page.
Pipeline Security Reviews Conducted, Fiscal Year 2010 through July 2018
aFiscal year 2018 data are through July 31, 2018.
bFiscal years 2010 and 2011 represent Critical Facility Inspections—the predecessor of the Critical Facility Security Review.
TSA officials stated that staffing limitations have prevented TSA from conducting more reviews. Staffing levels for TSA's Pipeline Security Branch have varied significantly since fiscal year 2010 with the number of staff ranging from 14 full-time equivalents in fiscal years 2012 and 2013 to 1 in 2014. Further, TSA does not have a strategic workforce plan to help ensure it identifies the skills and competencies—such as the required level of cybersecurity expertise—necessary to carry out its pipeline security responsibilities. By establishing a strategic workforce plan, TSA can help ensure that it has identified the necessary skills, competencies, and staffing.
GAO also identified factors that likely limit the usefulness of TSA's risk assessment methodology for prioritizing pipeline system reviews. Specifically, TSA has not updated its risk assessment methodology since 2014 to reflect current threats to the pipeline industry. Further, its sources of data and underlying assumptions and judgments regarding certain threat and vulnerability inputs are not fully documented. In addition, the risk assessment has not been peer reviewed since its inception in 2007. Taking steps to strengthen its risk assessment, and initiating an independent, external peer review would provide greater assurance that TSA ranks relative risk among pipeline systems using comprehensive and accurate data and methods.
TSA has established performance measures to monitor pipeline security review recommendations, analyze their results, and assess effectiveness in reducing risks. However, these measures do not possess key attributes—such as clarity, and having measurable targets—that GAO has found are key to successful performance measures. By taking steps to ensure that its pipeline security program performance measures exhibit these key attributes, TSA could better assess its effectiveness at reducing pipeline systems' security risks. Pipeline Security Branch officials also reported conducting security reviews as the primary means for assessing the effectiveness of TSA's efforts to reduce pipeline security risks. However, TSA has not tracked the status of Corporate Security Review recommendations for the past 5 years. Until TSA monitors and records the status of these reviews' recommendations, it will be hindered in its efforts to determine whether its recommendations are leading to significant reduction in risk.
Why GAO Did This Study
More than 2.7 million miles of pipeline transport and distribute oil, natural gas, and other hazardous products throughout the United States. Interstate pipelines run through remote areas and highly populated urban areas, and are vulnerable to accidents, operating errors, and malicious physical and cyber-based attack or intrusion. The energy sector accounted for 35 percent of the 796 critical infrastructure cyber incidents reported to DHS from 2013 to 2015. Several federal and private entities have roles in pipeline security. TSA is primarily responsible for the oversight of pipeline physical security and cybersecurity.
GAO was asked to review TSA's efforts to assess and enhance pipeline security and cybersecurity. This report examines, among other objectives: (1) the guidance pipeline operators reported using to address security risks and the extent that TSA ensures its guidelines reflect the current threat environment; (2) the extent that TSA has assessed pipeline systems' security risks; and (3) the extent TSA has assessed its effectiveness in reducing pipeline security risks.
GAO analyzed TSA documents, such as its Pipeline Security Guidelines ; evaluated TSA pipeline risk assessment efforts; and interviewed TSA officials, 10 U.S. pipeline operators—selected based on volume, geography, and material transported—and representatives from five industry associations.
Recommendations
GAO makes 10 recommendations to TSA to improve its pipeline security program management (many are listed on the next page), and DHS concurred.
GAO recommends, among other things, that the TSA Administrator take the following actions:
implement a documented process for reviewing, and if deemed necessary, for revising TSA's Pipeline Security Guidelines at defined intervals;
clarify TSA's Pipeline Security Guidelines by defining key terms within its criteria for determining critical facilities;
develop a strategic workforce plan for TSA's Security Policy and Industry Engagement‘s Surface Division;
update TSA's pipeline risk assessment methodology to include current data to ensure it reflects industry conditions and threats;
fully document the data sources, underlying assumptions and judgments that form the basis of TSA's pipeline risk assessment methodology;
take steps to coordinate an independent, external peer review of TSA's pipeline risk assessment methodology;
ensure the Security Policy and Industry Engagement‘s Surface Division has a suite of performance measures which exhibit key attributes of successful performance measures; and
enter information on Corporate Security Review recommendations and monitor and record their status.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Transportation Security Administration | The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to implement a documented process for reviewing, and if deemed necessary, for revising TSA's Pipeline Security Guidelines at regular defined intervals. (Recommendation 1) | We found that TSA's Pipeline Security Branch had revised its security guidelines in March 2018 to, among other things, reflect the dynamic threat environment and incorporate NIST's Cybersecurity Framework principles and practices. However, TSA had not instituted a documented process to consider the need to update the Pipeline Security Guidelines on a regular basis. As a result, we found that without a documented process defining how frequently TSA is to review and revise its guidelines, TSA could not ensure that its guidelines reflect the latest known standards and best practices for physical and cybersecurity. Therefore, we recommended that TSA implement a documented process for... reviewing, and if deemed necessary, revising TSA's Pipeline Security Guidelines at regular defined intervals. In response, in March 2019 TSA officials established an internal operating procedure that documents the review and revision process for all of TSA's surface transportation security guidance, which include its Pipeline Security Guidelines. Per the procedure, TSA's Surface Division is to review, and if deemed appropriate revise, its surface transportation security guidance to ensure they remain current and appropriate using risk-based principles on an annual basis. Further, TSA's Surface Division is to update its security guidance, at a minimum, every five years but may update them earlier if TSA determines that new or revised are in the public interest. These actions are consistent with our recommendation.
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| Transportation Security Administration | The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to clarify TSA's Pipeline Security Guidelines by defining key terms within its criteria for determining critical facilities. (Recommendation 2) | In December 2018, we reported on the Transportation Security Administration's (TSA) pipeline security program (GAO-19-48). During the course of our review, we found that TSA's Pipeline Security Guidelines for pipeline operators lacked clear definitions to ensure that pipeline operators identify their critical facilities. In addition, our analysis showed that operators of at least 34 of the nation's top 100 critical pipeline systems (determined by volume of product transported) deemed highest risk had identified no critical facilities. This might have been due, in part, to the guidelines not clearly defining the criteria to determine facilities' criticality. Consequently, we recommended...
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| Transportation Security Administration |
Priority Rec.
The TSA Administrator should develop a strategic workforce plan for its Security Policy and Industry Engagement's Surface Division, which could include determining the number of personnel necessary to meet the goals set for its Pipeline Security Branch, as well as the knowledge, skills, and abilities, including cybersecurity, that are needed to effectively conduct Corporate Security Reviews (CSR) and Critical Facility Security Reviews (CFSR). (Recommendation 3) |
In December 2018, we found that TSA had not established a workforce plan for its Pipeline Security Branch that identified staffing needs or cybersecurity skills required to best implement security reviews, such as the Corporate Security Reviews and Critical Facility Security Reviews. We recommended that TSA develop a strategic workforce plan that outlines the knowledge, skills, and abilities, including those related to cybersecurity, needed to effectively conduct pipeline security reviews. TSA's Human Capital Workforce Planning Division completed the Final Workforce Assessment Report in May 2021. The Assessment Report identified, among other things, several staffing inadequacies,...
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| Transportation Security Administration | The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to update the Pipeline Relative Risk Ranking Tool to include up-to-date data to ensure it reflects industry conditions, including throughput and threat data. (Recommendation 4) | In 2018, we found that the Pipeline Relative Risk Ranking Tool TSA uses to assess various security risks of pipeline systems had not been updated since 2014. For example, when the risk assessment was last updated in 2014, it used pipeline systems' throughput data from 2010 to assess relative risk. We determined that outdated data may limit the usefulness of the current risk assessment to allow the Pipeline Security Branch to effectively prioritize reviews of pipeline systems. As a result, we recommended that TSA update the Pipeline Relative Risk Ranking Tool to include up-to-date data to ensure it reflects industry conditions, including throughput and threat data. In December 2019, TSA...
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| Transportation Security Administration | The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to fully document the data sources, underlying assumptions and judgments that form the basis of the Pipeline Relative Risk Ranking Tool, including sources of uncertainty and any implications for interpreting the results from the assessment. (Recommendation 5) | We found that TSA had not fully documented sources of data and underlying assumptions and judgments regarding certain threat and vulnerability inputs for its Pipeline Relative Risk Ranking Tool. For example, the Pipeline Security Branch ranked threat equally across pipeline systems because officials said they did not have enough threat information to distinguish threat by pipeline. However, this judgment was not documented in the risk assessment's methodology. As a result, we recommended in December 2018 that TSA fully document the data sources, underlying assumptions and judgments that form the basis of the Pipeline Relative Risk Ranking Tool, including sources of uncertainty and any...
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| Transportation Security Administration |
Priority Rec.
The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to identify or develop other data sources relevant to threat, vulnerability, and consequence consistent with the National Infrastructure Protection Plan and DHS critical infrastructure risk mitigation priorities and incorporate that data into the Pipeline Relative Risk Ranking Tool to assess relative risk of critical pipeline systems, which could include data on prior attacks, natural hazards, feedback data on pipeline system performance, physical pipeline condition, and cross-sector interdependencies. (Recommendation 6) |
In December 2018, we found that TSA used a risk ranking tool that calculated threat, vulnerability, and consequence for pipeline systems on variables such as the amount of throughput in the pipeline system. However, we also found that incorporating additional factors that enhance security into TSA's risk calculation would better align their efforts with federal policy. Therefore, we recommended that TSA identify or develop other data sources relevant to threat, vulnerability, and consequence and incorporate that data into its efforts to assess relative risk of critical pipeline systems, which could include data on prior attacks, natural hazards, feedback data on pipeline system...
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| Transportation Security Administration |
Priority Rec.
The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to take steps to coordinate an independent, external peer review of its Pipeline Relative Risk Ranking Tool, after the Pipeline Security Branch completes enhancements to its risk assessment approach. (Recommendation 7) |
In December 2018, we found that TSA's pipeline risk ranking tool had not been peer-reviewed since its conception in 2007. In our past work, we reported that independent, external peer reviews are a best practice in risk management and that independent expert review panels can provide objective reviews of complex issues. Therefore, we recommended that TSA take steps to coordinate an independent, external peer review of its pipeline risk ranking tool, after the agency completed enhancements to its risk assessment approach. According to TSA, in February 2023 the agency initiated a contract with a vendor to review and update the tool. One of the contract requirements was a complete review of...
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| Transportation Security Administration | The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to ensure that it has a suite of performance measures which exhibit key attributes of successful performance measures, including measurable targets, clarity, and baseline and trend data. (Recommendation 8) | We found that TSA established performance measures to monitor pipeline security review recommendations, analyze their results, and assess effectiveness in reducing risks. However, these measures did not possess key attributes--such as clarity, and having measurable targets--that GAO has found are key to successful performance measures. Therefore, we recommended that TSA develop a suite of performance measures which exhibit key attributes of successful performance measures, including measurable targets, clarity, and baseline and trend data. In response, TSA provided us its updated performance measures and documentation in August 2020 which explained the methodologies for calculating each...
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| Transportation Security Administration | The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to take steps to enter information on CSR recommendations and monitor and record their status. (Recommendation 9) | We found that TSA conducts pipeline Corporate Security Reviews (CSRs), during which TSA staff make security-related recommendations to operators, if appropriate. For example, a CSR recommendation might include a suggestion to conduct annual security-related drills and exercises. However, TSA had not tracked the status of its pipeline recommendations for over 5 years. As a result, we recommended that TSA take steps to enter information on CSR recommendations and monitor and record their status. In April 2020, TSA provided documentation and explanations of actions taken to update and monitor CSR recommendations. Specifically, TSA issued a Pipeline Security Assessment Guidance document and...
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| Transportation Security Administration | The TSA Administrator should direct the Security Policy and Industry Engagement's Surface Division to improve the quality of its pipeline security program data by developing written documentation of its data entry and verification procedures, implementing standardized data entry formats, and correcting existing data entry errors. (Recommendation 10) | We found that TSA used several databases to store information related to TSA pipeline security assessments. We identified several problems with the databases that indicate that the pipeline security program data were not sufficiently reliable and do not provide quality information that is current, complete, and accurate. For example, one of the recommendation databases only included information for reviews conducted from November 2010 through February 2013 and data were missing or erroneously entered in many data entry fields. As a result, we recommended that TSA improve the quality of its pipeline security program data by developing written documentation of its data entry and...
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