Monday, November 23, 2009

DHS CSAT FAQ Page Update – 11-20-09

Last week DHS added four new questions to their CSAT Frequently Asked Questions (FAQ) web page. One question was already addressed here last week; the other questions were: 1648: How does a SSP user navigate through the SSP Tool? How are answers to questions saved in the SSP Tool? 1650: What happens after a facility submits its Site Security Plan (SSP)? 1651: How do I start an SSP? After Initial SSP Submission As more and more facilities complete the submission of their SSP the inevitable question is what happens next; that is answered in the response to question 1650. Once DHS receives the submission they will review the submission. The first review is largely automated; a check to see if all of the appropriate questions have been answered for all of the COI listed in the notification letter. Then a number of subject matter experts will review the details of the submission to see if the plan meets all of the requirements of 6 CFR 27.225. If all of the issues are adequately addressed, DHS will issue a ‘Letter of Authorization’ that ‘authorizes’ the facility to proceed with the implementation of the Site Security Plan outlined in their submission. DHS will then schedule a site inspection to determine if the facility is in compliance with their SSP. The inspectors will look at the existing and planned security procedures that are detailed in the submission to ensure their adequacy in meeting the risk-based performance standards outlined in the regulations. DHS has told Congress that they expect to start the inspections in December with priority being given to the Tier 1 facilities that were required to submit their SSP’s earlier this fall. If the facility’s SSP submission is inadequate, DHS has two different approaches that it can take. If the facility appears to be on the right track, but has some issues with its submission DHS will send the facility a guidance letter that outlines specific things that are missing or need clarification with the facility submission. Provisions are made for additional consultation with DHS to correct these deficiencies. As part of that consultation the facility might consider asking for courtesy inspection where an inspector will visit the facility to look at the facility’s situation and security measures. This visit will not be considered to be the SSP inspection. If the facility’s SSP submission is completely inadequate DHS may formally disapprove the SSP. The letter making that notification will outline the deficiencies in the SSP. Instructions on how to proceed and a new deadline for correcting those deficiencies will be included. Facilities should keep in mind that the Secretary has the authority to seek civil sanctions on non-compliant facilities including issuing a cease operations order until the facility is in compliance. One would assume that those options would be outlined in the notification of disapproval. SSP CSAT Tool Both of the other questions deal with the actual operations of the SSP tool. Facilities that have yet to start their SSP submission should read these two responses to reinforce the instructions provided in the SSP on-line instructions manual and the initial notification letter. The brief responses will not be an adequate substitute for reading the actual instructions, but do serve to re-enforce some key points.

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