For the last year or so we have been discussing CFATS inspections of facilities that have submitted their Site Security Plans (SSP). What has not been made real clear to many people (and I have been guilty of this myself) is that for the most part these inspections have not been the Authorization inspections described in the CFATS regulations. These are an additional set of inspections that ISCD has found necessary to implement because SSP submissions have not provided enough information for the review process at Headquarters to determine the adequacy of security measures.
The best description of this new Pre-Authorization Inspection (PAI) process that I have seen can be found in a white paper available through ChemicalProcessing.com. ADT has prepared this white paper; CFATS: Surviving the Site Security Plan. It is well worth reading as it addresses both the PAI and the strategy to avoid having to have the Chemical Facility Security Inspectors make the additional trip to your facility.
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