Today the folks at DHS ISCD updated some of the web sites
associated with the Chemical Facility Anti-Terrorism Standards (CFATS) program.
The updated pages include:
The changes were made to reflect the passage of HR 4007
during the last session. The only substantive change to date (beyond the
mention of the new CFATS authorization language) is a link to a copy of 6
USC §621 et seq. This is where the new CFATS authorization language is
found. Interestingly the Department had to use a congressional web site for
this link since the GPO
web site for the US Code is not due for the 2014 update for a couple of
months yet.
There is a brief mention of the new expedited approval
process for Tier 3 and Tier 4 facilities that I have previously described
in some detail. No details are provided beyond mentioning that DHS “expects
the guidance to be issued in the summer of 2015”. As I mentioned in an earlier
post, Congress set the deadline for publishing that guidance at 180 days
after passage of HR 4007 which would be July 16th.
I am surprised that DHS does not mention the grandfathering
of existing site security plans (SSPs) in these updated web pages. There has
still not been any official pronouncement about the status of SSPs approved
after December 18th. Those approved before that date will not have to
be renewed for the new CFATS authorization language by congressional mandate.
Plans approved after that date do not have that official protection.
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