Saturday, February 24, 2018

CFATS PSP ICR Revision Comments – 02-24-18

Back in December the DHS Infrastructure Security Compliance Division (ISCD) published a 60-day information collection request revision notice for proposed changes to the personnel surety program (PSP) for the Chemical Facility Anti-Terrorism Standards (CFATS) program. Comments on the proposed extension of the anti-terrorist screening requirement to Tier III and Tier IV facilities were solicited. The first comments were received this week.

Comments were received from (links are .PDF downloads):

Rather than the general opposition to the PSP process that marked many industry comments on earlier iterations of the PSP ICR process, these three comments raised some interesting questions (and generally provided potential solutions) arising from the expansion of the PSP terrorist vetting program.

Some detailed questions were raised about the assumptions that were made by ISCD for calculating the average burden estimate. It would seem that ISCD has a better basis for making these estimates now that they have worked closely with Tier I and Tier II facilities in implementing the PSP submissions, but legitimate questions have been raised about differences between the types of facility included in the two different risk categories of facilities.

There close of the comment period is Monday, so there is a decent chance that there will be more comments posted to the web site for this ICR. ISCD will take some amount of time to review the comments and address them as they determine appropriate. ISCD will then publish a 30-day ICR notice before sending the ICR to OMB for approval. It could still be six months to a year or more before OMB approves the expansion of the PSP terrorist screening process. And we have to remember that Congress will have a chance to weigh in on the process (again) when they (hopefully) reauthorize the CFATS program later this year.

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