Tuesday, January 11, 2011

OMB Approves Chemical Security Awareness Training ICR

Last Friday the Office of Management and Budget provided their approval of the information collection request (ICR) for the DHS Chemical Security Awareness Training Program. I have previously described this on-line training program that helps CFATS and non-CFATS covered chemical facilities train their employees on the types of security threats that they should be aware of while working at a variety of chemical facilities.

Since this ICR supports a voluntary training program, it really is a non-issue. Even though the previous ICR expired last October, it had no practical effect on the operation of the training program. This is just one of those bureaucratic ‘dot-the-i and cross-the-t’ exercises that Federal government agencies must periodically go through. The ICR approval process helps to ensure that the Federal government doesn’t impose undue burdens on the public, but that isn’t really an issue in this instance.

One of the reasons that I am ‘wasting’ time on reporting this approval today is that I always enjoy pointing out the silly mistakes that government agencies are prone to. I reported in an earlier blog that the OMB had the wrong date in their system for the publication date for the 30-day ICR notice in the Federal Register. Well, apparently no one at the OMB reads this blog because they continue to report the wrong date for the submission of that notice. Furthermore, the Federal Register Citation they provide for that 30-day notice is actually the citation for the earlier 60-day notice.

On a more controversial ICR this mistake might actually cause some sort of minor problem. In this case I really doubt that anyone is going to be going back to research the approval process of this ICR as part of any legal defense against a DHS enforcement action.

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