Sunday, March 31, 2013

CFATS PSP – Only Tier 1 and 2 Facilities Impacted

This is part of a continuing series of blog posts about the CFATS Personnel Surety Program that was described in a 60-day information collection request (ICR) notice in Friday’s Federal Register. This post will look at the decision to only apply this ICR to Tier 1 and Tier 2 facilities. The earlier posts in the series are listed below.

While the discussion through much of the ICR notice mentions all CFATS facilities, buried in the discussion of calculating the burden of the ICR is a statement that the ICR will only apply to Tier 1 and Tier 2 facilities.

Testing PSP
One of the suggestions that ISCD received after the last 30-day ICR notice was forwarded to OMB (and subsequently withdrawn) was that ISCD should do the same thing that it had done with most major CSAT tool deployments (excepting the SSP) and test the tool before it was officially deployed. This would allow the bugs to be worked out of the program.

While this probably would have been a good idea two years ago when the PSP was initially proposed (and before the Department started evaluating SSPs), this is no longer a reasonable prospect before the PSP ICR is submitted and approved. Too many facilities are receiving provisional authorizations for their SSP without a method being available to complete the personnel surety terrorist vetting required under RBSP #12.

Besides, even in conducting a test version of the PSP tool with live data (the only type of test that would be really worth while) would still require an approved ICR to collect the data and have it entered into the CSAT application. Thus the ICR must go forward without a live system test.

Limited PSP Implementation

ISCD has worked out a way to test the PSP application and the data collection and submission process from a variety of facilities, as well as evaluate the assumptions underlying the burden estimates in the ICR. They will limit the initial application of the PSP tool to just Tier 1 and Tier 2 facilities. They estimate that this will entail only 552 facilities and about 192,000 individual. This is compared to about 4,000 facilities and over 2 million individuals for a full deployment of the PSP.

Tier 3 and Tier 4 facilities are not being exempted from the PSP. ISCD intends that “ a subsequent ICR would be published and submitted to OMB for approval to incorporate any lessons learned and potential improvements to the CFATS Personnel Surety Program prior to collecting information from Tier 3 and Tier 4 high-risk chemical facilities” (78 FR 17696).

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