Monday, January 4, 2016

ACC and NACD Update CFATS Alternate Security Plan

Over the holidays the American Chemistry Council (ACC) and the National Association of Chemical Distributors (NACD) published a new updated version of the ACC’s Alternative Security Plan (ASP) for the CFATS program. The original version of the ASP was released three years ago as an easier way for regulated chemical facilities to submit site security plan (SSP) information for the Chemical Facility Anti-Terrorism Standards (CFATS) program.

The goal of the ASP program has been to not only make it easier to submit the information that the Infrastructure Security and Compliance Division (ISCD) of DHS needs to evaluate the SSP, but to also provide the submitting facility with a document that could actually be used in the implementation and day to day operation of the SSP.

The new program includes;

• An ASP Guidance Document (.PDF);
• An ASP Template (with instructions) (.DOCX Download); and
• A set of nine forms to be used with the ASP (.ZIP download)

A quick review of the literature associated with ASP II shows that it does include at least some information from the new legislation authorizing the CFATS program (the Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2014, PL 113-254), but it does not refer specifically to the new personnel surety program being rolled out by ISCD (understandable since many of the details of that program have yet to be published). It also does not address the Expedited Approval Program (EAP) initiated by ISCD this last summer as an alternative to both SSPs and ASPs.

Long time readers of this blog will undoubtedly remember that I was a big fan of the ASP when it was rolled out (see my series of blogs here). This looks like it will be a valuable update of that program. I am especially glad to see that the NACD has specifically signed on to this as a partner in the revised program.

I will be looking at this revised program in more detail in future posts.

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