Thursday, July 14, 2016

OMB Approves CSAT 2.0 ICR

Today the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that they had approved the DHS Infrastructure Security Compliance Division’s (ISCD) information collection request (ICR) revision for the Chemical Security Assessment Tool (CSAT). ISCD has been calling the revised CSAT tools ‘CSAT 2.0’, reflecting the underlying change in the risk assessment process.

As I understand things the approval of this ICR does not mean that ISCD will immediately change over to CSAT 2.0. Part of the reason is that they still have to get the risk assessment process up and running along with getting the other tools upgraded to the 2.0 version. The plan remains that CSAT 2.0 and the new risk analysis process will be made active sometime this Fall.

As I mentioned in an earlier post, ISCD will be publishing a notice in the Federal Register outlining the process involved in the change-over, including describing which types of facilities will be required to submit a new Top Screen to re-start the screening process. There is currently no indication that there will be a wholesale requirement for all CFATS facilities to re-do their Top Screens before currently required by regulations.

While I had been hoping that ISCD would be web casting their CSAT 2.0 demonstrations at the Chemical Sector Security Summit, but that is not going to happen. I have been hearing, however, that there will be some sort of future web casts of the various tools like the Top Screen web cast earlier this year.

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