DHS Publishes Three ICR Renewal Notices for CFATS

DHS published three information collection request (ICR) 60-day renewal notices in Monday’s Federal Register (available on-line today) supporting documentation requirements for the Chemical Facility Anti-Terrorism Standards (CFATS) program; Chemical Facility Anti-Terrorism Standards (77 FR  74677-74678), CFATS Chemical-Terrorism Vulnerability Information (77 FR 74685-74686), and Chemical Security Assessment Tool (77 FR 74678-74685). These would renew the current information collection authorities that expire on March 31, 2013.

Burden Information

Each of the ICR notices provides data on the burden the information collection request would place on the participants in the program. The table below summarizes the data presented in the three notices. It looks like there were errors made in the ICR preparation in two instances; I have included the apparently correct data in parentheses and the ‘correct’ data is used in my ICR total calculations (the notices do not provide summation data). The ‘previous ICR’ data comes from the OMB web site (links provided) for the latest approved version of the ICR, all dated March 19^th, 2010.

OMB#	Instrument	Respondents		Time	Cost Burden
1670-0014	Chemical Facility Anti-Terrorism Standards (CFATS)
	Request for Redetermination		625	156.25	$13,437
	Request for Extension		185	46.25	$3,977
	Notification of New Top Screen		1,250	468.75	$40,312
	Request for Technical Consult		185	69.37 (46.25)	$5,966 ($3,977)
	Total for ICR		2,245	3,269.5	$61,703
	Previous ICR - 2010		10,200	2,552	$897,700
1670-0015	CFATS Chemical-Terrorism Vulnerability Information (CVI)
	CVI Authorization		30,000	30,000	$2,580,000
	Determination of CVI		300	75	$6,450
	Determination of Need to Know		14,200	3,550	$305,300
	Disclosure of CVI		300	75	$6,450
	Notification of Emergency		300	75	$6,450
	Tracking Log		30,000	30,000 (2,499)	$2,580,000 ($214,914)
	Total for ICR		75,100	36,274	$2,929,564
	Previous ICR - 2010		321,323	35,387	$731,800
1670-007	Chemical Security Assessment Tool (CSAT)
	CSAT Top Screen		2,500	25,600	$2,203,700
	SVA		740	43,400	$3,730,900
	SSP		486	145,900	$9,675,200
	CFATS Helpdesk		15,000	2,250	$219,300
	CSAT User Registration		625	1,250	$107,500
	Request for Information		329	129 (329)	$10,500 ($28,294)
	Total for ICR		19,680	218,729	$15,964,694
	Previous ICR - 2010		45,937	764,995	$13,000,000

 

The only ICR notice that provides any sort of details about the methodology that was used in preparing the data was for the CSAT ICR. There is a detailed discussion about how DHS NPPD compared actual historical data to the original ICR (from 2007 for this particular ICR notice, not the latest ICR). I’m not sure that I specifically agree with the reasoning presented in every case, but the assumptions are all reasonably made.

It is interesting to note that each of the ICRs show a significant drop in the total number of estimated responses for the program. The total time required burden shows a relatively minor increase for two of the programs (CFATS and CVI) but a significant reduction in the number of hours for the CSAT program. Since the OMB files don’t show a breakout for the individual collection instruments it is difficult to make any judgments on the significance of these differences.

There is one internal discrepancy shown in my table. All of the currently approved ICRs show zero annual cost burden for these ICRs. This is very typical for the OMB site and I have objected to this in many of my blog posts about ICR approvals. These ICR renewal requests provide specific annual burden costs to industry (based upon $86.00 per hour salary for facility security officers according to the CSAT ICR notice) and I have summed those for the ‘Total for ICR’ line. The data for the ‘Previous ICR’ line comes from the OMB site as the “Annual Cost to Federal Government” on each ICR notice. This is certainly an apples and oranges comparison and must be viewed as such.

New Collection

The CSAT notice reports that the last information collection ‘instrument’ in the notice, “Request

for Information To Improve Program” (77 FR 74684), is a new instrument in the collection. It appears to be (from a very brief comment in the notice) a survey type thing where ISCD will email CSAT registrants some sort of questionnaire about CSAT documents (manuals and forms apparently). This will be done to improve the program. I’m not sure that OMB will approve a vague collection request like this, but it does sound like a reasonable (and appropriate) program. I certainly would like to see more information about this program published by ISCD.

Public Comments

As is always required by 5 CFR 1320.8 DHS NPPD is soliciting public comments on each of these ICRs. Comments on all three may be submitted via the Federal eRulemaking Portal (www.Regulations.gov) at the docket numbers listed below:

• CFATS Program ICR – Docket # DHS-2012-0059

• CFATS CVI Program ICR – Docket # DHS-2012-0057

• CFATS CSAT Program ICR – Docket # DHS-2012-0058

Comments on each need to be submitted by February 15^th, 2013

En Passant

 

None of these ICRs deal with the very long overdue CFATS Personnel Surety Program; just saying.