On January 6th, CISA published an advanced notice of proposed rulemaking (ANPRM) for “Removal of Certain Explosive Chemicals From the Chemical Facility Anti-Terrorism Standards”. This is part of a series of blog posts about the public comments submitted in response to that ANPRM. The earlier posts in the series were:
• Comments
on CFATS Explosive Chemicals ANPRM – 1-30-21
• Comments on CFATS Explosive Chemicals ANPRM – 2-14-21
This week there were three new comments submitted. All three supported the proposed rulemaking. The comments were from:
• Institute
of Makers of Explosives,
• Jason
Rawlings, Austin Powder Company, and
Cost of Compliance
The comments from IME include the results of an internal 2017 study of the cost of complying with the CFATS regulations for three different (unnamed) facilities. One-time costs ranged from $433,820 to $1,000,000. Recurring annual costs ranged from $70,400 to $125,000. Presumably, the costs cited are over and above the costs associated with BATF security regulations.
Commentary
These comments have done little to explicate why the CFATS security
costs are higher than those associated with the BATF regulations, nor have they
described why the added security requirements from the CFATS program are
unnecessary. If the added security measures mandated by the CFATS program to
prevent the theft of explosives from have not provided any additional benefit
as suggested by these commentors, then perhaps CFATS program should remove
those requirements from other facilities that possess the other non-explosive DHS
chemicals of interest with a theft/diversion security concern.
Posts
No comments:
Post a Comment