This is part of a continuing series of blog posts on the public comments submitted about the DHS 60-day ICR notice for the CFATS Personnel Surety Program (PSP). The other post in the series is:
This week there are comments from two industry organizations representing, hardly a well spring of comments as the fourteen day comment extension comes to a close. Effectively, there are just two days left in the comment period.
ISCD PSP Authority
The commentor representing terminal interests again objects to the ‘prescriptive’ nature of the PSP program proposed by ISCD and notes that this violates the §550 prohibition against the Secretary specifying any particular security measure as a prerequisite to site security plan approval. They even went so far as to include a 2012 letter they sent to the OMB after the previous attempted PSP ICR was forwarded to OMB for approval.
Alternative to PSP
The commentor representing the gas industry proposed an alternative proposal for a PSP program where individuals wishing to enter CFATS facilities submit information to a secure website for the purpose of being vetted against the Terrorist Screening Database. Once cleared, they would be given a personal identification number that they would provide to CFATS facilities to verify that they had been properly vetted against the TSDB. This is the same procedure that was proposed the week before by the chemical manufacturer.