Wednesday, September 3, 2014


It has been over two weeks now since DHS published their advanced notice of proposed rulemaking (ANPRM) on possible changes to the Chemical Facility Anti-Terrorism Standards (CFATS), but you would never know it by the two main web sites related to that program. Neither the Chemical Security landing page nor the CFATS Knowledge Center have so much as a mention of the ANPRM. We are now a quarter of the way through the public comment period and there has yet to be a notice of a single one of the public listening sessions promised in the ANPRM.

Now I understand that there has to be a certain amount of frustration over at ISCD about this rulemaking. First off the only requirement for looking at changes in the CFATS program mentioned in the President’s Executive Order on Increasing Chemical Safety and Security (EO 16350) was the requirement to look at possible changes to the DHS chemicals of interest list, making DHS look like the ugly step-child at the chemical safety and security party. Then, after they had worked so hard on the ANPRM it they don’t know whether or not Congress will act on HR 4007 and make the whole effort an exercise in futility.

Finally, to make matters even worse, there has not been a single comment posted to the docket for the ANPRM.  It is certainly too early for corporate comments, but not a single person has bothered to complain about the personnel surety program. Greenpeace has not weighed in on inherently safer technology.

Of course, if ISCD had discussed the ANPRM on their web sites… Or had published the date for the first public meeting… Or had even acknowledged that the ANPRM had been published… Then maybe there would be some public discussion about the ANPRM.

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