Monday, October 13, 2014

OMB Approves CSAT ICR Renewal

On Friday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved the DHS information collection request (ICR) for the on-line Chemical Security Assessment Tool (CSAT) that is used to collect program information from facilities affected by the Chemical Facility Anti-Terrorism (CFATS) program. The 30-day ICR notice for this collection was published back in March, 2013.

This announcement provides links to the supporting documents for this ICR. It provides a link to the American Chemistry Council comment [.PDF download link] that was responsible for the changes to the method of calculating the burden estimate for the SSP Tool. While DHS did modify their burden estimate, it seems clear to me that there is still some level of disagreement about how they calculate the hours of support activity that goes into the SSP documentation. 

While this disagreement is not fully explained in the ICR documentation I suspect that it relates to how much of the time that the ACC is claiming for SSP burden is used for preparing the SSP data submission and how much is for the preparation of the SSP. It would be helpful if the folks at the DHS Infrastructure Security Compliance Division (ISCD) would explain this distinction.

NOTE: The other two CFATS ICR’s (CVI and CFATS) that were submitted at the same time as this were approved on September 30th. I did not report them here as they were both submitted as renewals without revision. The length of time necessary for the approval of these ICR’s is almost certainly a measure of the political problems that the CFATS program has been facing in Congress. It is apparent that these have been approved now as a result of the apparent change in the support for HR 4007 in the Senate. We still have one CFATS ICR outstanding and that is the one for the CFATS Personnel Surety Program; due to congressional (read industry in this case) opposition to the way ISCD has structured that program the ICR will not be approved.

No comments:

/* Use this with templates/template-twocol.html */