Wednesday, February 20, 2013

ACC ASP Press Release

I got a nice email from Scott Jenson, Director of Issues Communication, American Chemistry Council, providing me with a copy of the press release about their CFATS Alternative Security Program. Reader’s will remember my detailed review of this template for submitting the information necessary for ISCD to evaluate a facility site security plan.

ISCD Endorsement

I’ve been a little disappointed that ACC hasn’t been a more proactive in publicizing this outstanding tool. Reading this press release it is clear to see why Scott and his people have held off. In the press release there is a link to a very kind letter from David Wulf, Director, Infrastructure Security Compliance Division, essentially endorsing the ACC ASP. David says, in part:

“Thank you especially for ACC's efforts to help high - risk chemical facilities meet the CFATS requirements through the development of the ACC Alternative Security Program ( ASP) Guidelines and Template . We commend your decision to make these documents available to all facilities regulated under CFATS for potential consideration and reference in the development of other ASPs.”

There is no date on the Wulf letter, but I’m assuming that as soon as ACC had this letter in hand, they started immediate work on this press release. This is a very valuable endorsement. I would like to join David in commending ACC for sharing this tool with the whole of the regulated community, not just their member organizations.

BTW: It would be nice to see some mention of this ASP somewhere on the DHS Chemical Security web page. A mention of the ACC ASP with a link to the document would make it easier for non-ACC members to avail themselves of this tool.

ISCD Promises Better SSP Performance

David takes the opportunity in this letter to address the continued slow pace of SSP approvals. He notes that ISCD has streamlined the authorizing and approval process and then reports that ISCD has set “set a goal of 400 approvals [emphasis added] by the end of 2013”. This would be a truly remarkable accomplishment since the last official number that I had seen on approvals was that only 2 had been completed. Even at this rate they will only have about 1/3 of the SSPs approved before they have to go back and start re-evaluating SSPs that were previously approved.

Actually, ISCD has not approved any SSPs yet. They have only given provisional approvals because facilities can still not comply with the Terrorist Screening Database vetting requirements of Risk-Based Performance Standard 12. Metric 12.4 for all four Tier levels states that:

“Processes are in place to provide DHS with the necessary information to allow DHS to screen individuals (e.g., employees, contractors, unescorted visitors) who have access to restricted areas or critical assets against the TSDB.”

Since ISCD has not yet even published their proposed procedures for this vetting process, facilities are not able to comply with this requirement. ISCD is over four months late (based upon a promise made by Undersecretary Beers in testimony to a Congressional Committee) in the publication of the 60-day information collection request (ICR) in the Federal Register. If this were to be published today it would still be nearly the end of the year (best case) before final OMB approval could be given to begin the collection of the information necessary for this vetting.

So it will be nearly impossible for ISCD to achieve their goal of 400 approvals by the end of the year. I’m all for setting high goals David, but they must be achievable.

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