There is an interesting blog posting over on the ChemicalProcessing.com web site dealing with the SSP inspection process describing a presentation made by Richard Cary, an ISCD Regional Commander (for chemical facility security inspectors). That presentation at the recent NPRA Security Conference in Houston, TX provided an overview of what facilities can expect from the SSP inspection process, though it isn’t clear from the blog whether this referred to the pre-authorization inspections (PAI) or the authorization inspection, or perhaps (more likely I expect) both.
Interestingly, the blog post provides a link to the CFATS web site page that deals with the inspection process. Unfortunately that page provides more of an overview of the CFATS process rather than any real information on the inspection process. It would seem to me that this web page would provide a better venue for ISCD to provide detailed inspection planning information to the regulated community.
I have seen similar information posted in other locations, but it is always valuable for facilities to hear what they can expect from the inspection process. It allows them to better prepare for their actual inspections.
One piece of information provided in this blog posting that I haven’t seen elsewhere deals with corporate issues. The blogger (I’m not sure if it’s Ryan Loughin or Steven Partridge, both from ADT) notes that: “One of the first things to know is that DHS will visit your company's headquarters prior to facility inspections. This will help companies with multiple facilities falling under CFATS. The three area commanders will coordinate headquarter visits for companies with sites in more than one region or jurisdiction.”
Not only would this make it easier for management with multiple CFATS sites, but it should make it easier for the CFATS inspectors to check those portions of the security program that are administered at the corporate level. Those could include items like the personnel surety program, customer vetting and order processing.