Friday, January 18, 2013

ISCD Blog Post

Yesterday afternoon David Wulf, Director of the DHS Infrastructure Security Compliance Division {the CFATS/Ammonium Nitrate Security Program (ANSP) people} provided the folks at SOCMA with a post on their blog site. It was a brief and positive update on the progress that his folks have been making on improving the CFATS program, both accomplishments to date (200 SSPs authorized and 22 approved) and future actions.

SOCMA is to be commended for offering Mr. Wulf the opportunity as is the Director for taking advantage of the offer. Communications between the regulators and the regulated are always a good thing.

Missing Information

Now I fully understand that a single blog post is not the best way to communicate complex information (I have heard complaints about the length of some of my posts). And, the problems at ISCD are certainly complex and cover a wide range of areas. But there were a number of things not addressed in David’s post. They include (in no particular order of importance) the status of:

• The publication of the Personnel Surety Program;

• The MTSA harmonization effort;

• The update of the COI list;

• The update of the CVI rules for the Controlled Unclassified Information Initiative

• The temporary agricultural facility Top Screen exemption; and

• The publication of the Ammonium Nitrate final rule.

Personnel Issues

There are also more than a few issues dealing with personnel matters within ISCD that I would have liked to have seen addressed. I understand the reluctance to talk about internal problems, but they do affect the operations of the Division and have at least some impact on the SSP approval process. There are three that I specifically wish to see ISCD discuss in public:

• Branch Chief Status (conversion of ‘temps’ to ‘permanent’);

• Turnover in the Chemical Security Inspector ranks; and

• Training program for CSI.

Now I understand that there is some concern within the National Protection and Programs Directorate (NPPD) about the number of their employees that have been unofficially (and anonymously) contacting me about these personnel issues. I have heard rumors that Deputy Undersecretary Spaulding has directed ISCD to reach out to me about this ‘problem’.

So, I would like to take this opportunity to offer to Mr. Wulf or any of his Branch Chiefs the unrestricted opportunity to post information in my blog about any of the issues identified above (or any other of their choosing really). It can take the form of a blog post or even written responses to questions submitted by me. If anyone at ISCD thinks that they have appropriately addressed these issues in some other public venue, please point me at the links and I will publish those.

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