Saturday, March 16, 2013

NPPD Publishes Three CFATS 30-day ICR Notices

The National Protection and Programs Directorate of DHS is publishing three 30-day information collection request (ICR) renewal notices in Monday’s Federal Register (78 FR 16692-16694, 78 FR 16694-16698, and 78 FR 16698-16699). These are all renewals of existing approved ICRs so it does not include the CFATS Personnel Surety Program ICR that Under Secretary Beers said would be published this coming week.

The ICRs

Most agencies feel free to include separate ICRs for a single program into a single notice, but NPPD separated them into three notices even though most of the administrative verbiage is the same. The three ICRs (with annual number of expected responses, total annual time and cost burden) are:

Chemical Facility Anti-Terrorism Standards (CFATS), OMB Number - 1670-0014 (60-day ICR notice - 77 FR 74677):

• Request for Redetermination – 625 responses, 156.25 hours, $13,437;
• Request for an Extension – 185 responses, 46.25 hours, $3,977;
• Notification of a New Top Screen – 1250 responses, 468.75 hours, $40,312; and
• Request for a Technical Consultation – 185 responses, 69.37 hours, $5,966.

• Chemical-terrorism Vulnerability Information Authorization – 30,000 respondents, 30,000 hours, $2,580,000;
• Determination of Chemical-terrorism Vulnerability Information (CVI) – 300 respondents, 75 hours, $6,450;
• Determination of a ‘Need to Know’ by a Public Official – 14,200 respondents, 3,550 hours, $305,500;
• Disclosure of Chemical-terrorism Vulnerability Information (CVI) Information – 300 respondents, 75 hours, $6,450;
• Notification of Emergency or Exigent Circumstance – 300 respondents, 75 hours, $6450; and
• Tracking Log for Chemical-terrorism Vulnerability Information (CVI) Received – 30,000 respondents, 30,000 hours, $2,580,000

Chemical Security Assessment Tool (CSAT), OMB Number - 1670-0007 (60-day ICR notice - 77 FR 74678):

• CSAT Top-Screen – 2,500 respondents, 42,500 hours, $3,655,000, revised up;
• Security Vulnerability Assessment – 740 respondents, 65 hours, $6,212,900, revised up;
• Site Security Plan – 486 respondents, 164,100 hours, $15,302,800, revised up;
• CFATS Helpdesk – 15,000 respondents, 2,250 hours, $219,300
• CSAT User Registration – 625 respondents, 1,250 hours, $107,500
• Request for Information to Improve Program – 329 respondents, 122 hours, $10,500

The revision of the three CSAT tools was brought about by a comment on the 60-day notice filed last December. The unnamed commenter took objection to the use of 2 hours of off-line work for every two-hours spent inputting information into the tool, suggesting that it should be more like 25-hours. NPPD conducted further investigations and determined that a more appropriate number would be 4 hours for every hour on-line. The numbers of respondents and hours needed for data input were not changed.

I am very pleased that NPPD continues to include an estimated facility cost for these data collections. I have no way of knowing how accurate the estimates are, but they do give us an idea of how expensive the CFATS program is from an administrative point of view. The total estimated annual cost for all three ICRs is $31,056,542. And remember, these are just the administrative costs, costs that do not produce one iota of security.

Submission to OMB

These three ICR renewal requests will be submitted to OMB in about 30-days. Comments on the renewal requests should be sent to OMB’s Office of Information and Regulatory Affairs (

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