Wouldn't be difficult for badguys to fabricate these things.
But not to steal one, especially near an industrial area meant to keep loose cars from rolling onto the spur line. I see lots of them and they are not very well maintained.
Here’s a link to a good AP photo of the curve just before the site of derailment.
No unusual objects. But it is a pretty good curve.
Easy to fabricate. And you can bet they wouldn’t paint it yellow. Or hang the blue MOW flag on it..