Sunday, April 14, 2013

CFATS PSP Comments – 04-13-13

This is part of a continuing series of blog posts on the public comments submitted about the DHS 60-day ICR notice for the CFATS Personnel Surety Program (PSP). The other post in the series is:

There has been only a single comment filed in the last two weeks, another comment by an individual with no identified connection to a covered chemical facility. It includes discussions about the relative benefits of Options 1 and 3. Unfortunately the opening and closing paragraphs that bracket that discussion demonstrate a significant misunderstanding of the proposal (noting that there is nothing that describes what will be done with people identified with terrorist ties) and the CFATS program (noting that there is nothing in §550 or the ‘proposed rule’ that defines ‘high-risk chemical facility). Those misunderstandings severely detract from the discussion of the two options in the notice.

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