Thursday, August 21, 2008

Another Alternate SVA Approved

The National Association of Chemical Distributors (NACD) announced that the security vulnerability assessment (SVA) methodology that they had developed for use by chemical distributors has been accepted by the Center for Chemical Process Safety (CCPS) as consistent with their SVA criteria. The NACD SVA Methodology for Chemical Distribution Facilities was specifically designed to deal with the security issues associated with chemical distributors.


Alternate Security Plans


As I noted in an earlier blog (see: “SVA for Tier 4 Facilities”), the CFATS regulations provide that high-risk chemical facilities that have been given a preliminary tiering assignment of Tier 4 may submit an alternate security plan (ASP) instead of completing the CSAT on-line SVA. DHS has the sole authority to accept or decline, in whole or in part, any such alternate security plan.


Since DHS based their SVA on work done by the CCPS, it is presumed that an SVA methodology that has been accepted by the CCPS as meeting their SVA criteria will have a high probability of being approved as an acceptable ASP. It is not a guarantee of approval. It just means that an SVA properly conducted with a CCPS ‘approved’ methodology will probably meet most of the DHS criteria for acceptance.


Why Allow the Use of an ASP


DHS originally included the ASP process to allow relatively lower risk high-risk facilities to use previously done security work to fulfill the CFATS requirements for SVAs and site security plans (SSP). The idea was that the hard work that had already been done did not need to be duplicated if it met the DHS standards for the work. DHS will allow an ASP to substitute for a CSAT SVA for Tier 4 facilities and for a CSAT SSP for all but Tier 1 facilities.


It is not clear that using the NACD SVA Methodology fits into this model. Facilities that used this SVA method to conduct their SVA before June 23rd of this year (the date DHS introduced the CSAT SVA to the public) are meeting the original intent of the ASP rule. Those that start using the NACD SVA now do not meet that intent. It is unlikely that DHS will differentiate between the two cases when making their decision to accept or decline the ASP as a substitute for the CSAT SVA.

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