It has been over a week now since the end of the federal funding fiasco and I think we can assume that the DHS ISCD folks are now back on track with their continuing implementation of the CFATS program. Here is a short list of output from ISCD that I would like to see in the coming weeks and months.
• November CFATS Status Update will be due soon;
• 30-day CFATS Personnel Surety Program ICR;
• Proposed revisions for Appendix A (for Chemical Safety and Security EO – 11-5-13 Deadline);
• Report on CFATS data sharing with SERCs, TEPCs, and LEPCs (for Chemical Safety and Security EO – 11-5-13 Deadline);
• Report on CFATS data sharing with EPA and OSHA (for Chemical Safety and Security EO – 11-5-13 Deadline);
• NPRM for Ammonium Nitrate Security Program; and
• Final action resolving ‘temporary’ agricultural producer’s exemption for Top Screen.
I had included the October CFATS Status Update when I initially wrote this, but ISCD was faster than my posting. They have just published a link to that update on their Critical Infrastructure: Chemical Security web site. I’ll have more on that this evening.
Now those are all things that are supposed to be in progress. Now for some innovative ideas that I would like to see suggested by ISCD:
• Proposal for alternative methods of certifying Site Security Plans for Tier 3 and Tier 4 facilities;
• Proposal to tie CFATS to security programs for truck and train transportation of hazardous material, particularly COI;
• Proposal to identify other potential CFATS facilities based upon CFATS facility customers and vendors of CFATS COI;
I’ll keep an eye out.