Thursday, January 3, 2013

Reader Comment – 1-2-13 – ACC Comments on ASP

Bill Erny, the Senior Director for Regulatory and Technical Affairs at the American Chemistry Council, left an interesting comment on my first blog post (BTW: there should be at least one more posting in that series, probably this weekend) about the establishment of the Alternative Security Program (ASP) developed by that organization. While all reader comments are appreciated, it is particularly nice to have input from people directly involved in the development of important programs like this one (HINT: Is anyone in ISCD willing to comment?).

Time Savings

Bill did take exception to my comment:

“One thing is very clear to me, it is going to take much more work to complete the ACC ASP than it would be to answer the questions in the DHS SSP.”

He responded:

“However, your observation that the ASP would take more work to complete is not actually the case. In fact, the opposite was reported by several owner/operators who were involved in the pilot testing and said that the ASP saves significant time over the SSP. This is true mainly due to the amount of duplication that is eliminated in the ASP versus the SSP.”

This would certainly be true if the facility in question was already providing the level of detail really required for the proper analysis of the Site Security Plan submission. Since most facilities are not giving ISCD enough information I, think I’ll stand by my comment. But please don’t misunderstand me; this is almost certainly a good thing. A little extra time ensuring that facility submits the required information will save time in the long run as ISCD will not have to conduct Pre-Authorization Inspections with all of the follow-up delays that that has been causing.

More Useful Information

Bill makes another interesting point that should be obvious in retrospect:

“The DHS field inspectors who participated in the pilots also reported that the ACC ASP offers a significant improvement over the SSP for use during auditing.”

The data format in the current SSP data submission tool (I really do hate that DHS calls this a site security plan) is designed to be used by a computer, not people. Printing out a copy of the SSP submission has got to be one of the greatest wastes of trees in the federal bureaucracy. The ACC ASP, on the other hand should read and feel like an actual security plan for the facility. It should be a document that people at the facility should actually be able to use in the management of the plan and it will be a very helpful document for anyone that wants to audit the program.

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