HR 4007 – The Clock Starts Ticking

This is part of a continuing discussion of the recently passed HR 4007, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2014. The President signed HR 4007 on Thursday so that is when the deadlines start (the important milestone dates for the program are shown below). The previous postings in this series were:

HR 4007 Sent to the President

HR 4007 – An Overview

HR 4007 – Implementation Deadlines

HR 4007 – Current Site Security Plans

HR 4007 – Expedited Approval Facility

New CFATS Deadlines

January 17^th, 2015

Effective Date of Title XXI;

Repeal of conflicting provisions of current regulations

March 18^th, 2015

Have facility outreach program established

June 16^th, 2015

Publish guidance for Expedited Approval Facility

July 16^th, 2015

Start point for 120 day deadline for current Tier 3 and Tier 4 facilities to submit EAF site security plans

November 13^th, 2015

Deadline for current Tier 3 and Tier 4 facilities to submit EAF site security plans

Grandfathered SSPs

All site security plans approved by DHS as of December 18^th are grandfathered by law. SSPs approved between that date and the date of new CFATS regulations may be grandfathered by Secretarial discretion.