Sunday, April 9, 2017

DHS Publishes Another CFATS ICR Revision

The DHS National Protection and Programs Directorate (NPPD) published another information collection (ICR) revision notice in Monday’s (available on-line yesterday) Federal Register (82 FR 17270-17273) supporting the Chemical Facility Anti-Terrorism Standards (CFATS) program. The requested revisions are due, in part, to the recent changes made to the Chemical Security Assessment Tool (CSAT) now known as CSAT 2.0.

The ICR (1670-0014) covers information collected via the following CFATS activities:

The changes reported here are all relatively innocuous and reflect bureaucratic i-dotting and t-crossing more than any shift in policy or procedures. Normally, I would not have mentioned this ICR notice at all (hardly newsworthy), but given the problems that I have identified with another ICR revision notice (from the TSA) I thought that I would mention this ICR notice and hold it out as an example of an agency providing detailed enough information for members of the public and affected community to be able to formulate an effective comment on the substance of the burden estimate provided by the agency.

The earlier TSA proforma ICR notice provided less than the minimum necessary information and left me with a better understanding of the agency’s reputation for blatant disregard of public opinion. That TSA notice, and their reply to my comment, clearly explicated to anyone that cared to listen that the TSA does not care how their activities affect those that they are supposed to be supporting.

DHS, and yes even the OMB’s Office of Information and Regulatory Affairs, could be well served by using this NPPD ICR notice as a teaching guide as to how a public ICR notice should be prepared and the earlier TSA notice as a counter-example.

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