Wednesday, February 27, 2013

TSA Publishes 60-day ICR Renewal Notice for Pipeline CSR

Yesterday the Transportation Security Administration (TSA) published a 60-day information collection request (ICR) renewal notice in the Federal Register (78 FR 13075-13076). This ICR supports the TSA Pipeline Corporate Security Review Program.

Pipeline CSR Program

According to yesterday’s notice the Pipeline Corporate Security Review Program is designed to allow the TSA to:

• Develop first-hand knowledge of a pipeline operator's corporate security policies and procedures;
• Establish and maintain working relationships with key pipeline security personnel; and
• Identify and share smart security practices observed at individual facilities to help enhance and improve the security of the pipeline industry.

The TSA inspector conducting the review uses a Pipeline Corporate Security Review form (TSA Form 1604) to both serve as a guide to the discussion about the pipeline security program at that facility/organization and to document the results of the review.

The Original ICR

The original ICR for this program was approved in 2010. It noted that the CSR would involve 12 reviews per year and that each review would take about 8 hours to complete. The ICR reported an expected annual burden cost of $11,076 (@ about $115/hour).

The original 60-day ICR notice noted that there was a potential universe of 2200 organizations at which a CSR could take place. That notice also noted that there would be a follow-up visit at one or two of an organization’s field locations to assess how well the organization was actually implementing their corporate pipeline security plan. That comment was not present in the subsequent 30-day ICR notice nor was there any indication of follow-up visits in the approved ICR.

The current ICR expires on May 31st, 2013.

Information provided to the TSA in these reviews will be protected under the Sensitive Security
Information (SSI) program in accordance with procedures meeting the transmission, handling, and storage requirements of SSI set forth in 49 CFR parts 15 and 1520.

Updated ICR

The only substantive change in this ICR notice is that TSA is now expecting to conduct 15 CSR’s per year instead of 12. This would increase the burden time to 120 hours per year. The notice does claim that there will be no cost burden to respondents.

Public Comments

TSA is soliciting public comments on this ICR renewal. Comments may be submitted by email ( Comments must be submitted by April 29th, 2013.

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