Wednesday, April 7, 2010

Reader Comment 04-03-10 CG Inspectors II

Last Saturday Anonymous left a response to a blog post written back in February about Coast Guard Inspectors. Based upon the lengthy observations about CG Inspectors, it is clear that Anonymous has some experience at MTSA facilities. I certainly appreciate those observations since I have little personal experience with these types of facilities, so I depend on Reader input. For CFATS facilities the final comment by Anonymous is most important; Anonymous wrote:
“Bottom line: Whether the industry is looking forward to new CFATS regs and the inspectors which come with them or not, it will be refreshing to have a cadre of inspectors who have undergone fairly extensive (and specific) training in the regulations, have ‘real-world’ experience (hopefully), and who are empowered to 'change gears’ based on what they are seeing in front of them during the inspection (ie. type of facility, location of facility, etc).”
Actually, the Infrastructure Security Compliance Division (ISCD) of DHS has gone even further than this; they don’t allow Chemical Facility Inspectors to ‘change gears’, they require it. Each facility will be inspected according to its compliance with its submitted and approved Site Security Plan (SSP). Inspectors might have an informal checklist of what to check at the facility, but it will be based upon that facility’s SSP, not some national standard. Some people at DHS have described the approved SSP as a ‘security contract’ with the individual facility. The negotiations of the provisions of that facility unique document is one of the reasons that DHS is having problems getting their inspection program moving forward as fast as some would like to see it move. Inspectors cannot go out and inspect a facility until there is an agreed upon SSP to inspect.

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