Friday, January 18, 2008

After the Top Screen

With the Top Screen deadline being next week, most facilities (hopefully) that are going to be designated High-Risk facilities will have all ready completed their Top Screen and have received their notification that they “may be regulated” by electronic notification after submission. These facilities will have started to turn their thoughts towards the next step in the CSAT process the Security Vulnerability Analysis (SVA)/

Letters should be going out shortly to those facilities that have received a preliminary designation as a high-risk facility. According to Attachment C to the CSAT Top-Screen User Manual those letters will notify the facility:

1.      They have been given a preliminary designation as a high-risk facility, and

2.      Their Tier ranking (Tier 1 – highest risk, Tier 4 – Lowest risk), and

3.      The security issues (Release, Theft/Diversion, etc) and chemicals that must be addressed in their SVA, and

4.      The date by which their SVA must be completed, and

5.      If the facility has received a preliminary tier ranking of #4, that they may submit an Alternative Security Plan.

Tier 1 facilities will be given the earliest submission dates for their SVA. This is part of the DHS strategy of giving first priority to the highest risk sites. Given their limited manpower this is the only strategy that makes sense. Unfortunately for those Tier 1 facilities, it also means that the facilities with the hardest SVAs to complete will probably have the shortest time within which to complete their work.

The SVA will be submitted on-line through the same secure web site that DHS used for the submission of the Top Screen. The only personnel that will be able to access that site are the Preparer and Submitter previously registered on the CSAT. If the facility needs to change one or both of these individuals prior to the new submission, the procedures can be found in the CSAT User Change Request Guide, available on-line.

DHS has not yet published a set of instructions for completing the SVA submission. This is probably the reason that none of the Phase II facilities has yet been notified of the date that their SVA is due. The facilities that completed their Phase 1 Top Screen submissions last summer were supposed to have received their letters in September so they should have completed their SVAs last month. The lessons learned from those submissions (presumably made with active DHS assistance as were their Top Screen Submissions) are almost certainly being incorporated in the instructions.

For those Tier 4 facilities that do not want to wait for the SVA instructions to be published to start work on their Alternative Security Plant, the easiest thing to do is to get a copy of  "Guidelines for Analyzing and Managing the Security Vulnerabilities of Fixed Chemical Sites." This book is producedby the Center for Chemical Process Safety. Any alternative plan must conform to the standards set forth in this book. They also have a web site that lists those SVA procedures that they have already reviewed and certified as conforming to their standards.

Actually, any facility that is required to submit an SVA to DHS would probably do well to get a copy of this book. While the DHS SVA is not going to be identical to the CCPS SVA, it was the starting point for the development of the DHS program. Studying this book will almost certainly make it easier to complete whatever vulnerability assessment the chemical facility is going to undertake.

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