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About Me
- Patrick Coyle
- I spent 15 years in the US Army as an Infantry NCO. After getting out of the Army I started working in the chemical industry, getting my BSc Chemistry degree while working as a technician. I spent 12 years working as a process chemist in a specialty chemical company. I'm now working as a QA Manager in a specialty chemical manufacturing facility. Email - PJCoyle@aol.comTwitter - http://twitter.com/pjcoyle
1 comment:
Although the information in FAQ 1658 is correct; the following except from the dhs/chemicalsecurity website providess incorrect information. It should be noted that ALL tiered facilities are permitted to submit ASP's in lieu of the DHS' SSP. Tier 4 facilities may submit an Alternative Security Program (ASP) for the Department of Homeland Security to consider in accordance with 67 CFR 27.235(a). Tier 3 and 4 facilities may choose to submit an Alternative Security Plan for the Site Security Plan for consideration by the Department in accordance with 6 CFR 27.235(a). Also, for clarity the following sentence from the DHS website (http://www.dhs.gov/files/programs/gc_1185897486043.shtm#2) should read: Facilities that complete the CSAT Top Screen and do not meet the consequence thresholds DO NOT need to comply with CFATS. NOT: Facilities that complete the CSAT Top Screen and do not meet the consequence thresholds are do not need to comply with CFATS. From IFR page 17704 section 6. Alternate Security Programs With respect to SSPs, the Department will permit facilities of all tiers to submit ASPs to satisfy the requirements of this rule. Also, In § 27.235(a)(1)–(2), A Tier 4 facility may submit an ASP in lieu of a Security Vulnerability Assessment,Site Security Plan, or both. Tier 1, Tier 2, and Tier 3 facilities may submit an ASP in lieu of a Site Security Plan. From http://www.dhs.gov/files/programs/gc_1185897486043.shtm#2 Risk-Based Facility Tiering Preliminarily tier 1, 2, and 3 facilities must subsequently submit a CSAT Security Vulnerability Assessment. Tier 4 facilities may submit an Alternative Security Program (ASP) for the Department of Homeland Security to consider in accordance with 67 CFR 27.235(a). Tier 3 and 4 facilities may choose to submit an Alternative Security Plan for the Site Security Plan for consideration by the Department in accordance with 6 CFR 27.235(a). Facilities that complete the CSAT Top Screen and do not meet the consequence thresholds are do not need to comply
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