EAF SSP Submissions

The post below has incorrect information - for the correct process for submitting EAP submissions see my post at - http://chemical-facility-security-news.blogspot.com/2015/07/eap-submission-process-simplified.html  Posted 07-22-15 4:30 CDT.
 

Readers of this blog have seen me comment on the upcoming submission of expedited approval facility (EAF) site security plans (SSP) for the DHS Chemical Facility Anti-Terrorism Standards program for a couple of months now. All along I have been predicting that the Infrastructure Security Compliance Division (ISCD) would probably be establishing a new Chemical Security Assessment Tool (CSAT) tool for the on-line submission of the EAF SSP. Well, it appears that I was wrong.

I learned today that EAF facilities (starting July 16^th) will be able to start submitting their EAF SSP vis the current SSP Tool. The procedure that will be used will be very similar to that used for the submission of Alternative Security Plans (ASP).

Preparation

The first thing that the facility Submitter is going to need to do is to print a hard-copy of the CSAT SSP Questions Manual. Put pages 3 thru 49 in a binder and place a CVI Cover Sheet on the front and rear of the binder. Mark each of the pages from the manual with the following:

“WARNING: This record constitutes Chemical-terrorism Vulnerability Information controlled under 6 C.F.R. § 27.400. Do not disclose to persons without a “need to know” in accordance with 6 C.F.R. § 27.400(e). Unauthorized release may result in civil penalties or other action. In any administrative or judicial proceeding, this information shall be treated as classified information in accordance with 6 C.F.R. §§ 27.400(h) and (i).”

Now fill in all of the blanks that apply to your facility. Many of these will already be filled in (pre-populated) when you get to the on-line tool, but having all of the information in one place will make things much easier when you start completing the SSP.

Next you will want to get the DHS Guidance for the Expedited Approval Program. You can either print out the blank pages 60-61 and 64 thru 91, or fill them out on your computer and then print them out. The hard copy of page 61 will have to be signed by the facility owner. They would then be scanned as a single document so that an electronic copy can be uploaded to CSAT. I would then recommend that the hard copies be put into the same binder as the SSP Questions Manual pages. Fortunately you don’t have to worry about the CVI marking of these pages, ISCD has already done that.

Finally you are going to need an electronic copy of a facility site map or diagram, the more detailed the better and electronic copies of photographs of the facility, preferably at least one overhead shot and one of each COI storage area. Since they are going to be submitted as part of your SSP they should be electronically marked as described above.

Submission

The rest is time consuming, more than a little tedious, but rather simple. Sign on to CSAT go to the SSP tool and start filling out the responses to the questions using the binder prepared above. If there is a sever discrepancy between the binder data and any data that is prepopulated in the SSP (and it appears that the on-line data is incorrect), contact the CFAT Help Desk {(866) 323-2957} before proceeding.

Once you complete answering the questions on page 49 from the SSP Questions Manual the next screen should be the ASP Questions. Or it may possibly be a new page for similar EAF program questions (I haven’t actually seen these pages now). In any case, there will be a small number of questions about the data that you are going to submit. Answer those questions and upload the EAF document and photographs. There will be a couple of ‘are you sure you want to submit this now’ questions and then you are done.

When to Submit

If your facility had received its final tiering notice before June 16^th and your facility had notified ISCD on June 16^th that you intended to submit an EAF SSP, then you can start submitting your EAF SSP on July 16^th (next Thursday). If you notified ISCD after the 16^th you have 30 days from the date of that notification.

If you had received your final tiering notification before June 16^th you have until November 13^th to complete your EAF SSP submission. Your EAF notification letter from ISCD will confirm the date you can begin submission and the date by which that submission must be completed.