Wednesday, July 14, 2010

CSSS Presentations – CFATS Update

As I promised last night, I will be taking a detailed look at the 19 presentations DHS put on the Chemical Sector Security Summit web site yesterday. Now I can only see the presentations I don’t have any way of hearing what the presenter said and that is frequently the key to understanding PowerPoint® presentations. Lacking DHS posting videos of the actual presentations (which I would really like to see them do), I’ll just have to read the slides and use my knowledge of the CFATS program to fill in the blanks. So keep that in mind when you read these blogs. I’ll start of, appropriately enough, with Sue Armstrong’s opening presentation of the Summit; “Update on Implementation of the Chemical Facility Anti-Terrorism Standards and Development of Ammonium Nitrate Regulations”. Sue started off with a basic rundown of where the CFATS implementation stood. Her presentation provided the numbers we saw earlier this week in the Roberts Law Group blog on the CSSS. One of the interesting background pieces of data not previously reported is the use of corporate reviews/inspections as part of the SSP inspection process. Ms Armstrong notes that there have been three of these reviews done “representing partial inspection of dozens of facilities” (slide 6). Since much of the site security plan can be held in common throughout a company (personnel surety, cyber security, ‘know your customer’ plans, etc) it certainly makes good sense to inspect these common items just one time. She notes that when DHS makes the initial contact on a ‘pre-authorization inspection’ they will ask the facility if a corporate review is appropriate. Sue briefly touched on a new program that provides for communications between DHS and other Federal agencies and State governments on CFATS matters. This CFATS Share Portal is probably set up via the Homeland Security Information Network (HSIN) and is designed to provide “situational awareness of CFATS covered facilities and potential risks associated with those facilities” (slide 9). These government officials must be CVI Authorized Users and have a need to know (as determined by ISCD HQ) to get access to this portal. She also addressed the CFATS staffing issue, reporting that ISCD now has 168 personnel on board with 100 more positions being filled by this fall. Of this there are 11 regional commanders and 77 chemical inspectors with 20 new inspectors currently in training. The remainder would be working in HQ taking care of the admin stuff as well as doing the hand reviews of the Top Screens, SVAs and SSP submissions. There is no mention if ISCD is still using contractors to do part of the CSAT submission reviews. Ms Armstrong also mentions some outreach brochures that ISCD has developed and started to distribute to help get the word out about CFATS. She specifically mentioned two; one for college and university labs and another for emergency responders. It would be very nice if these were available somewhere on the CFATS web site; the CFATS Knowledge Center would be an excellent place for the links to be located. There were two slides dealing with the very late ammonium nitrate program. Nothing that wasn’t discussed last year in much more detail. This includes the promise of an NPRM “this fall”. Hopefully we will actually see one this year. One item that was missing in this year’s presentation was the amount of money in the budget request for the AN program in the FY 2011 budget.

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