Thursday, July 2, 2009


Yesterday in the Federal Register the National Protection and Programs Directorate, Office of Infrastructure Protection, DHS, filed the initial 60-day notice of their intent to file a new information collection request (ICR) to authorize collection of new/additional information from high-risk chemical facilities in support of the Chemical Facility Anti-Terrorism Standards (CFATS, 6 CFR Part 27). DHS expects to use these new requests for information as the Site Security Plan assessment process moves forward. Comments on this new ICR should be filed before August 31st via (docket number DHS-2009-0035) Four new data collection documents are named in this notice. They are the:
Request for Redetermination Request for an Extension Notification of a New Top Screen Request for a Technical Consultation
No further descriptions of the documents are provided in the ICR notice other than the estimate that it will take approximately 15 min (0.25 hrs) to complete each of the forms. Further, DHS notes that it expects to receive a substantial number of request, ranging to as many as 6250 for the ‘Notifications of a New Top Screen’ to a low of as few as 1041 submissions of the Request for Redetermination. With the 15 minute estimated time to complete the forms it may be that DHS is intending to include these forms in the CSAT tool. This would avoid potential problems with inadvertent disclosure of CVI during the submission since that submission would be made via the secure CSAT web-site. More information should be available when DHS posts their next notice for this ICR since that will be part of the actual submission to OMB.

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