Today CISA published a 60-day information collection request (ICR) supporting the Infrastructure Protection Division’s ChemLock program. According to the ChemLock home page:
“CISA's ChemLock program is a completely voluntary program that provides facilities that possess dangerous chemicals with no-cost services and tools to help you better understand the risks you face and improve your chemical security posture in a way that works for your business model.”
The ICR would address three separate information collection processes. The table below shows the burden estimate for each of those processes:
Note: The table includes slightly different ‘Burden’ numbers than those found in the text of the notice; I calculated the burden from the response and time information provided in the text. If the time figures are rounded that could account for the differences.
Request for Comments
CISA is soliciting comments on this ICR notice. Comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov, Docket # CISA-2024-0034). Comments should be submitted by March 3rd, 2025.
Commentary
CISA has been using a version of the request for services
form (and probably the other two forms as well) for a little over three years,
so technically they have been in violation of 44
USC 3507(a). Having said that, since the program is voluntary, they have not
been requiring anyone to provide the requested information. With the death
of the CFATS program, I would bet that the ChemLock program is receiving
more attention within the Agency and that has probably lead to the identification
of this technical violation within the agency. It would also explain why the
information provided in the notice is not up to the standard set by the CFATS
program that was run by the same division of CISA.
For more information on the forms covered in this ICR, see
my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/publish/post/153860717
- subscription required.
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