Saturday, July 21, 2012

OMB Announces Withdrawal of CFATS Personnel Surety ICR

Yesterday the Office of Management and Budget (OMB) announced that DHS/NPPD had withdrawn the information collection request (ICR) necessary to implement the CFATS personnel surety program. This is the program that would have ISCD collect personnel information on facility personnel and visitors with unaccompanied access to high-risk chemical facilities to check those personnel against the Terrorist Screening Database (TSDB). This check is required for Risk-Based Performance Standard #12.

There was no indication in the notice why the ICR had been withdrawn, but this ICR has been opposed by industry as overreaching. It has also been criticized by many members of Congress on both sides of the aisle for not utilizing the TWIC, or at least formally recognizing the TWIC, as the method of vetting personnel with unaccompanied access to high risk chemical facilities. One would hesitate to suggest that political considerations were behind the NPPD action.

One would like to think that the formal withdrawal of this ICR would be an indication that the Infrastructure Security Compliance Division (ISCD) has a new personnel surety program ready for release in the near future. Perhaps there will be an announcement about this program that will be made in association with the Chemical Sector Security Summit at the end of the month.

Of course the problems that we have been seeing with the failure to release new guidance on the SSP implementation process probably argues against any quick resolution to the personnel surety problem. ISCD is getting further and further behind and it is fast reaching the point where if significant progress is not seen in the near future, we should seriously consider disbanding ISCD and re-starting the CFATS program from scratch.

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