Thursday, May 14, 2015

EAP Guidance – SSP Status

This is part of a continuing series of blog posts on the newly released Expedited Approval Program (EAP) guidance document for Tier 3 and Tier 4 facilities under the Chemical Facility Anti-Terrorism Standards (CFATS) program. Other posts in the series are:

I have noted in a couple of these blog posts that it has been unclear how a Tier 3 or Tier 4 facility’s SSP status affects their ability to file an SSP under the EAP process. Obviously newly tiered facilities that have not yet submitted an SSP may choose this option. The question really applies to those facilities that have already started the SSP process; either having submitted an SSP or ASP via CSAT, have hand their SSP or ASP authorized by DHS, or even have had their SSP or ASP approved by DHS.

For informational purposes, here is the latest information available for the SSP status of Tier 3 and Tier 4 facilities

SSP Authorized
SSP Approved
Tier 3
Tier 4

I have been told that any Tier 3 or Tier 4 facility, regardless of the status of their SSP are eligible. Specifically I was told that even facilities with an approved SSP can use the EAP process. It is not yet clear how this will all be done; we will have to wait and see what new Chemical Security Assessment Tool (CSAT) applications are provided for the EAP process. It looks like we will see the first one on June 16th; that will be the tool for notification to DHS that a facility intends to apply for an EAP SSP.

What this does mean is that every Tier 3 and Tier 4 CFATS facility owes it to themselves to closely review the EAP guidance and determine if it makes sense to change their current SSP (at whatever stage in the process) to an EAP SSP.

One other thing to take into consideration is that it appears that ISCD is intending to prioritize the compliance inspections of EAP facilities. This makes a great deal of sense since no one in ISCD is actively involved in reviewing the details of the EAP SSP the way that they are during the standard SSP process. In effect, the compliance inspection will be the first time that ISCD has a chance to see how the EAP SSP is implemented at that particular facility.

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