Friday, March 27, 2009

DHS Presents CFATS Update at ChemSecure

I had hoped to get to ChemSecure, the ACC Chemical Security Conference in Houston, this week; unfortunately my personal economy is in no better shape than that of the country as a whole. I had particularly wanted to get to this conference because it looked like it would be the first conference after DHS released the new RBPS Guidance Document and the SSP roll out. I was really looking forward to the DHS presentation on CFATS. Last weekend when I found out that DHS could not roll out the next stage of CFATS because of the continuing review of the RBPS Guidance document by OMB, I was less disappointed. Another part of me still wanted to go just to see how well the DHS presenters filled up their assigned time while saying essentially nothing about SSP and RBPS. Well, I did not get to see the presentation, but I have gotten hold of a copy of the DHS slides. It looks like I missed out on a good presentation, but I still do get to talk about it. One caveat, I have copies of the slides but I did not hear the words that were spoken with them. A good presentation is a lot more than just the information on the slides. Updated Top Screen Results DHS provided some interesting figures on results from Top Screens. The slide repeated the June 2008 figure of about 7,000 high-risk facilities and then reported that the current number has dropped to 6,419. This is one area where I would have liked to hear the explanation, but I can make some educated guesses about the 10% drop. With the number of chemical facilities that have shut down, cut back or slowed down, I would bet that the economy is a large factor in the drop in high-risk chemical facilities. If I were a facility manager for a high-risk chemical facility that had cut inventories to reflect current production needs, I would certainly try to ensure that my COI were among the chemicals whose inventories were reduced. Once some of those COI levels were below STQ amounts, I would immediately re-submit my Top Screen. I would hope to get bumped off the high-risk list, or at least have my Tier level changed. This may be reflected in another figure on the Top Screen slide. The bottom line on the slide shows that DHS is still receiving Top Screen submissions at the rate of about one per week. I would have loved to ask how many of those submissions are from new facilities and how many are essentially re-submissions. SVA Results Actually there were no SVA results presented. Since DHS has not yet made any notifications to facilities they would be reluctant to discuss results. They are not making notifications because that would start the SSP submission clock and DSH still does not know for sure when they will be able to roll out the SSP. The SVA slide did still get a chance to provide some interesting information. First all of the SVA’s from facilities with preliminary Tier 1 status have been submitted and DHS is prepared to make notification when SSP becomes available. DHS hopes to make Tier 2 notifications in April, Tier 3 in June and Tier four in August. I expect that those times may slip as they want to give their greatest attention to the Tier 1 facilities when the SSP becomes available. There were two pieces of numerical data on this slide. First the slide notes that there were still 40 Tier 3 SVA’s due with a due date of 3-25-09. Since the initial Tier 3 SVA’s were due on November 24th this looks unusual. This could mean that these facilities were not in the original June 2008 notifications because of new first time Top Screen submissions. Or there could have been requests for SVA extensions requested and approved by DHS. Finally there could have been Tiering downgrades because of resubmission of Top Screens. We have a similar data point provided in the Tier 4 listing. The SVA slide shows that there have been 3142 SVA’s submitted, but the Top Screen slide showed that there were currently 3943 Tier 4 facilities. The difference of 801 facilities is probably due to similar circumstances examined for the Tier 3 numbers. Site Security Plan Update This was, of course, the area that I had hoped for the most information, but DHS just could not provide it while the RBPS is still under review. We did find out that the SSP tool on CSAT is ready to go (unless major revisions are required for RBPS). It has been field tested at 9 facilities of various types that volunteered to be guinea pigs. That was probably a good move on the part of the facilities; get brownie points and free help at the same time. One interesting looking item is not totally clear due to the use of acronyms that I am not familiar with; again they would have been explained in the actual presentation. What I do understand is that DHS is working with TSA and SCO (?) to develop an on-line portal to allow facilities to check employee names against the TSDB (Terrorist Status Data Base, I think, but certainly the terrorist database by some name) which is ‘required’ for RBPS #12, Personnel Surety. DHS expects that this will be operational in October (the same month that CFATS is technically slated to turn into a pumpkin). One final thing that is interesting is something that I cannot figure out from the slide so it grabs my attention. Can someone translate the following for me? “PIA and SORN under review” There are more slides, but I’ll save them for another day.

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