Tuesday, April 28, 2020

OMB Approves CISA CI Workers Denied Movement Reporting ICR

Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved an emergency information collection request (ICR) from the Cybersecurity and Infrastructure Security Agency to collect information on Critical Infrastructure Workers Denied Movement Reporting. An on-line form would be used by CISA designated Essential Critical Infrastructure Workers (ECIW) to report incidences where local law enforcement agencies denied their movement to or from designated critical infrastructure facilities.

According to the Supporting Document submitted to OIRA by CISA (pg 1, section 1):

“As part of our routine monitoring or our programs, we have heard anecdotal evidence that even though our non-mandatory guidance [See Version 3.0 of the Essential Critical Infrastructure Workers list] has been adopted, local Law Enforcement are not fully following this guidance and have restricted entities that are excepted by local rules. CISA has a duty to evaluate the risk of this behavior. The proposed collection will not attempt to rigorously validate or measure the prevalence of these incidents, but represents an important first step in better understanding the issue.”

CISA will post a copy of the proposed form [.PDF download link] on its web site for ECIW to use in reporting these incidents.

OIRA approved the emergency collection for six months. OIRA noted in their ‘Terms of Clearance’ that:
“The agency will not use the anecdotal information collected for statistical purposes to form the basis of a justification for further guidance or rulemaking efforts.”

The emergency ICR approval process allowed CISA to submit the ICR to ORIRA without going through the normal 30-day and 60-day ICR publication process.


This is an odd little ICR. I am not sure how much of an issue this ‘problem’ is (and apparently neither does CISA), but I suspect that CISA will not have an easy time reaching their target audience to collect this data. Since my day job is in one of the ECIW positions, I will be watching for messaging about this collection effort.

One added thing about this ICR is that the submission must have been something of a rush effort at CISA. Whom ever prepared the submission paperwork did a simple (and quick) cut and paste effort. The submitted Supporting Statement (.PDF download link) contains a number of references [See page 6, section 16 for instance] to ‘NPPD’, the agency which pre-dated the formation of CISA.

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