Saturday, November 28, 2015

Supervisory Chemical Security Inspector Openings

Yesterday the DHS National Protection and Programs Directorate (NPPD) published a job listing on for seven Supervisory Chemical Security Inspector. The job listing closes next Thursday, December 13th, 2015.

Multiple Locations

Interestingly, there are twenty potential locations listed for the seven job openings. The locations listed can be found in the following states:

• Arkansas;
• California;
• Florida;
• Louisiana;
• Minnesota;
• North Carolina;
• Ohio;
• Oklahoma;
• Pennsylvania;
• South Carolina; and
• Texas.

Ammonium Nitrate Security Program?

The most interesting part of the announcement can be found in the Job Summary portion near the top of the page:

“Are you interested in a job where your primary purpose will be to plan, organize, schedule and conduct on-site inspections of ammonium nitrate facilities? Then consider joining the Field Operations Branch, Inspections and Enforcement Branch (I&EB), Infrastructure Security Compliance Division (ISCD), Office of Infrastructure Protection (IP), National Protection and Programs Directorate (NPPD), Department of Homeland Security (DHS).”

I reported earlier that the Ammonium Nitrate Security Program rulemaking had been moved to the ‘Long Term Action’ section of the Unified Agenda. That would seem to indicate that there would be no near term (next year at least) action on publishing a final rule. The reason, of course, is that DHS is having a hard time figuring out a cost effective method of meeting the Congressional mandate (see 6 USC Subchapter VII, Part J) to “regulate the sale and transfer of ammonium nitrate by an ammonium nitrate prevent the misappropriation or use of ammonium nitrate in an act of terrorism”. In fact, the Appropriations Committees of both the House and Senate have suggested that the folks at ISCD should craft a new NPRM instead of trying to twist the previous NPRM into a workable final rule.


While the first two duties listed in the job listing deal directly with security of ammonium nitrate facilities, the CFATS program is mentioned in one of the five job duties listed:

“Providing policy analysis, oversight, and technical expertise on legislation and regulations to the national Chemical Facility Anti-Terrorism Standards program by assessing, interpreting and implementing regulatory requirements.”

Then when we look at the qualifications requirements for being considered for this position we see the requirement for at least one year’s experience in:

• Evaluating subordinate chemical inspector preparation, performance, and reporting on chemical facility inspections;
• Reporting on chemical facilities by utilizing the Chemical Facility Anti-Terrorism Standards (CFATS);
• Collaborating and maintaining working relationships with business and industry representatives, • Federal, State and local government agencies, and internal and external stakeholders to revolve problematic issues and ensure legal compliance; and
• Supervising the work performance of other chemical facility inspectors.

Moving Forward

It looks like DHS is looking to establish the initial cadre of folks that will be starting up the Ammonium Nitrate Security Program. Since it looks like these folks will probably be hired from the existing pool of GS 13 Chemical Security Inspectors, I doubt that it will take the normal six to nine months to fill these positions. So it looks like we may see some movement (at long last) on establishing the ANSP. 
BTW: The ANSP final rule was supposed to be finished in 2008, according to the authorizing legislation. DHS only managed to get the comment period on the ANPRM completed by December 29th, 2008. This has been much more difficult than Congress ever imagined.

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