Wednesday, July 6, 2016

Top Screen Freeze

I have been receiving questions from folks in the field about the ‘Top Screen Freeze’ that is in effect at the DHS Infrastructure Security Compliance Division (ISCD). While I have written about the new Top Screen rollout, the recent questions have been about Top Screens being submitted now.

ISCD ‘Freeze’ Guidance

I have gone back to my contacts at ISCD and obtained a copy of the memorandum that DHS sent to CFATS facilities back on June 21st, 2016. There is nothing in that memorandum that contradicts what I said in my last post on this topic. It does, however, provide some additional information:

“In anticipation of publication of the Federal Register notice [see more below], and to minimize duplication for facilities, DHS is planning to slow down and in some cases suspend the review of some Top-Screens and SVAs [Security Vulnerability Assessments]. DHS will automatically extend due dates for facilities that have Top-Screens and SVAs due in the coming weeks. These extensions will release facilities from the requirement to submit a Top-Screen or SVA until the Federal Register notice is published announcing the formal suspension [emphasis added]. Facilities should contact their Chemical Security Inspector [CSI] or Compliance Case Manager [CCM] with any questions or for clarifications on next steps.”

This certainly makes sense, both for ISCD and covered facilities. No one is well served by duplicative work. Facility specific questions should be addressed to the facility CSI or CCM. Facilities without contact information for these individuals should contact the CFATS Help Desk {(866) 323-2957}.

Federal Register Notice

Before ISCD can proceed with the changes to the CSAT tool (now being referred to as CSAT 2.0) it must wait on the OMB’s Office of Information and Regulatory Affairs’ (OIRA) approval of the CSAT information collection request (ICR) revision that I talked about in the Top Screen Rollout blog post. There is no telling when that ICR approval will be given; the personnel surety program ICR took more than a year to get approved. The CSAT 2.0 ICR is certainly less controversial and everyone at ISCD expects the approval process to be much quicker.

Once OIRA approves the ICR revision ISCD will be publishing a notice in the Federal Register outlining the details of how CSAT 2.0 will be rolled out. As mentioned above, part of that notice will be an official suspension of the Top Screen and SVA submission requirements pending the actual start dates of the new CSAT tools. It is possible that ISCD will publish their Federal Register notice before the OIRA CSAT 2.0 ICR approval, but there are potential problems with such a move if OIRA drags out the ICR approval process.

2016 CSSS

This is a topic that will certainly be discussed at the upcoming 2016 Chemical Sector Security Summit CSSS. The Agenda shows that there will be two workshops on July 19th demonstrating the CSAT tools; presumably these will be the CSAT 2.0 tools. Unfortunately, none of the workshops are currently planned to be web cast. I certainly hope that ISCD reconsiders this, especially given the number of questions from the field about these new tools.

On the 20th there will be a session on “Infrastructure Security Compliance Division Regulatory Update”. I expect that Director Wulf will be discussing the CSAT 2.0 implementation in some detail during this hour long presentation. This will be web cast.

If you have not yet registered to attend the CSSS in person or via the web cast there is still time to register.

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