Tuesday, July 7, 2009

CFATS Background Check ICR Comments – 07-02-09

Last month I wrote a short blog posting about the Information Collection Request that DHS had published for their planned program for providing high-risk chemical facilities with checks of the government’s Terrorist Screening Database (TSDB) for facility employees, contractors, and others that would be granted unaccompanied access to critical areas of the facility. I noted in that posting that comments could be submitted to the www.Regulations.gov web site. ICR requests seldom get much response from the public, but I periodically go back and check anyway. As of last Friday, there were two short comments posted for this ICR. Comments were provided by: Scott Kirby Cambell Anonymous Scott Kirby Cambell Comments Mr. Cambell notes that commenting on this ICR in a public forum is constrained by the fear of disclosing ‘confidential information’. The ICR notice does not provide a procedure for filing comments that include CVI. While I can’t imagine what CVI information would be necessary to justify a comment on this ICR (that may just be my lack of imagination), I would recommend that anyone wishing to include such information should contact the CSAT Help Desk (866-323-2957) for assistance. Mr. Cambell also makes the statement that: “Screening every unescorted visitor for potential terrorist ties (ie: truck drivers) to a high risk facility is an impossible task.” If one assumes that all visitors to the high-risk chemical facility will be given unaccompanied access to that facility, then Mr. Cambell is absolutely correct. What DHS assumes is that as part of the Site Security Plan, these facilities will prohibit most people from having unaccompanied access, reserving that for people with a clearance (background check and TSDB check) and a need for unaccompanied access. All other would have their movements restricted to certain areas of the facility or would require escorts. He also asks: “How is the FBI terror watch list maintained? It seems, from different analysis I've read, that there is no standard method for review of this list.” This ICR does not reference an ‘FBI terror watch list’. It refers to the TSA operated Terrorist Screening Database (TSDB). Any employee, contractor or other regular visitor to a high-risk facility that had been submitted to this new CSAT Tool who showed up on the TSDB would have a their information turned over to the Terrorist Screening Center for additional investigation. Anonymous Comments Anonymous asks “Will a TWIC card satisfy all the requirement standards? Since personnel who have received a TWIC will have already undergone a check against the TSDB, a facility would not be required to re-submit their information for another check. The potential problem with this is that most non-MTSA covered facilities will not have a TWIC Reader (when those Reader’s ultimately become available) to be able to verify that the TWIC card biometrically matches up with the holder. At some point, DHS will have to require that the use of the TWIC will only be an acceptable method of identification if a TWIC Reader or functional equivalent is available to verify the identity of the person and authenticate the TWIC.

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