Thursday, November 16, 2023

CSAT ICR Renewal Approved by OMB

Yesterday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved an information collection request (ICR) renewal from CISA for “Chemical Security Assessment Tool (CSAT)”. The 60-day ICR notice was published on December 12th, 2022 and the 30-day ICR notice was published on April 20th, 2023. Nothing of specific interest with the updated data in the ICR, but it is odd that the OMB has approved the ICR for a terminated program.

A large number of industry organization and governmental agencies, not to mention looky-loos like myself, are hoping that Congress gets its proverbial act together and reauthorizes this valuable chemical facility security program, but as time drags on without such action it is becoming increasingly more likely that nothing is going to get done. The fact the OMB has taken this relatively routine action with this ICR, reminds us of the fact that the structure of this program still exists and just needs a relatively simple congressional action to allow it to be resuscitated.

I wonder if OMB could approve the notice of proposed rulemaking by CISA on “Chemical Facility Anti-Terrorism Standards (CFATS)”? It was submitted to OIRA before this ICR. Not likely, but it could provide further incentive for the Senate to act.

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