Monday, April 6, 2020

CFATS PSP Instructions Not Available 4-6-20

Today the Chemical Facility Anti-Terrorism Standards (CFATS) program landing page was updated with a reference to the signing into law of the  Coronavirus Aid, Relief, and Economic Security (CARES) Act. That act extended the CFATS program authorization until July 23rd, 2020. As is usual when this page is updated, I went back and reviewed some of the sub-pages to the web site, looking for changes. Instead of finding any significant changes I found that there was no longer any actual link to the Personnel Surety Program (PSP) instruction book. This would be the Chemical Security Assessment Tool (CSAT) manual for completing the PSP program submissions.

There are two different paths that people should be able to use to get to the PSP manual. Both start on the landing page. The first (and shorter path) goes:

3. Guidance Document  back to #2.

The second path goes:

5. Guidance Document back to #4

The unintended loop set up by the ‘Guidance Document’ (different links for the two apparently identical versions) in the two paths is what prevents folks from getting to the actual document. None of the other CSAT instruction manuals have a ‘Guidance Document’ link. That makes a certain amount of sense since these are not (for the most part) guidance documents, but instructions for using the on-line tools. Why the PSP instructions need the guidance document disclaimer is not clear.

I cannot tell when this manual became unavailable. For the most part DHS stopped dating their web site pages some time ago. Because of the involvement of the ‘Guidance Document’ linkage in the problem, I suspect that this dates back to the DHS implementation of Executive Order 13,891, Promoting the Rule of Law Through Improved Agency Guidance Documents, in February of this year.

By the way, I went back to the latest link that I have for the document and that returns a ‘Page Not Found’ page. This is unusual, these older links typically remain active for quite some time.

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