OMB Approves Renewal of TSA CCSP ICR

On Friday the Office of Management and Budget (OMB) announced that they had approved the information collection request (ICR) renewal submitted by TSA for their Certified Cargo Screening Program (CCSP). The ICR renewal was submitted as a revision of the currently approved collection and was approved by OMB without change from what TSA requested.

As requested by TSA the approved ICR shows a large reduction in the estimated number of expected responses and burden hours. The number of expected annual collections reduced from 724,774 to 127,050 and the hours burden reduced from 718,482 to 143,768. As TSA explained it this way in their renewal application:

“TSA estimates for expected CCSP enrollments have decreased, resulting in a reduction in estimated burden. In light of this reduction in expected CCSP enrollment, TSA eliminated the TSA-approved validation firms from the CCSP in favor of continued TSA assessments. This eliminated the collection instruments and burdens associated with these firms.”

As I noted in my blog post on the 60-day ICR notice the situation is a little more complex than that. The original ICR was based upon the interim final rule for Air Cargo Screening (74 FR 47672) which included provisions for private sector entities doing validations of facilities doing air cargo screening and included air lines in the CCSP. The final ACS rule (76 FR 51848) eliminated both of those classes of respondents; the first because of the smaller number of facilities enrolling in the program allowed TSA to do the validations in-house; the second because the airlines were covered under a separate program.

Again, we see no estimated cost burden on the regulated community for collecting, maintaining and submitting the information required under the Air Cargo Screening rule. Only the federal government could assume that there was no cost associated with these actions.

TSA Air Cargo Screening ICR Renewals

Yesterday the Transportation Security Administration submitted their 60-day information collection requests renewal notices for two separate ICRs (1652-0040 and 1652-0053) in support of their Air Cargo Security Requirements program and the Certified Cargo Screening Program.

Typically these ICR renewals are not a big thing; just a rehash of old information necessary to keep the ICR files up to date. The numbers (number of submissions required and total response time requirements) are frequently just a cut and paste operation, but sometimes some interesting and often unexplained changes are included. That appears to be the case here.

Air Cargo Security ICR

This ICR is in support of TSA activities required under the Aviation and Transportation Security Act (ATSA; PL 107-71) for screening all property that will be carried aboard a passenger aircraft and the establishment of a system to ensure the security of cargo being carried on all-cargo aircraft. The individual collections covered under this ICR renewal, the expected number of annual submissions and the time needed to complete those submissions is listed below. The previous ICR was approved on 4-8-11 and expires on 4-30-12.

1652-0040	Submissions	Time
Initial Security Program	152	608
Security Program Updates	4,509	18,036
Security Program Appeal	42	210
STA	40,003	10,001
STA Record Keeping	40,003	3,334
KSMS	92,000	26,400
KSMS Manual	8,000	8,000
CSRI	135	6,994
CSRI Record Keeping	40,003	3,334
Total	840,138	44,728
Previous	884,844	73,567

 Air Cargo Security Requirements ICR Data

NOTE: KSMS - STA - Security Threat Assessment; Known Shipper Management System; CSRI - Cargo Screening Reporting Information

There are two reasons for the differences between the totals listed in the table above and the data from the previous submission. First TSA added the ‘STA Record Keeping’ to the ICR (NOTE: That was not specifically mentioned in the ICR though it probably should have been.).

The figures in the ‘Time’ column are my calculations not the numbers from the ICR as I noted three discrepancies; the ISP figure in the ICR was 606 not 608, the CSRI figure in the ICR was 6994 not 7020; and the CSRI Record Keeping figure was 3320 not 3334. The last was due to a rounding issue for the digital equivalent of 5 minutes (.083 vs .0833…) and may be a federal standard. I don’t know where the other two errors crept into the system but they have been included in previous ICR’s.

Certified Cargo Screening ICR

This ICR renewal is in support of the TSA’s certified air cargo screening program. Adoption of the final rule for this program last summer modified the necessary information collections to support that program and greatly reduced the number of submissions (127,050 down from 724,774) and the time required to submit the required information (143,785 hours down from 718,482 hours). That reduction was due to the elimination of the provisions regarding validation firms and dropping the requirements for airlines to become certified cargo screeners.

The individual collections covered under this ICR renewal, the expected number of annual submissions and the time needed to complete those submissions is listed below. The previous ICR was approved on 4-8-11 and expires on 4-30-12.

1652-0053	Submissions	Time
CCSF Application	967	1,934
STA Applications	51,172	12,793
Security Programs	593	24,906
Security Program Updates	1,234	4,936
Record Keeping	51,172	4,264
Cargo Reporting	21,912	94,952
Total	127,050	143,785
Previous	724,774	718,482

Certified Cargo Screening Program ICR Data

NOTE: CCSF - Certified Cargo Screening; STA - Security Threat Assessment

The only new item included in this ICR is the provision for 593 new Security Program submissions; why this was not included in the previous ICR is not explained. There is an odd omission from the information collections listed in this (and previous versions of this) ICR. There is no provision for record keeping for the Security Threat Assessments as seen in the Air Cargo Security ICR.

Congressional Hearings Week of 11-15-10

With Congress starting back up from their long election recess there looks to be a lot of work that will need to be completed before the end of the year. Part of this work is to conduct some investigative hearings for recent security incidents. There are two such hearings scheduled for this week that might have implications for the chemical security community. And of course there is the Stuxnet hearing I’ve already mentioned.

Air Cargo Security

The Senate Homeland Security and Governmental Affairs Committee will be holding a hearing on November 16th at 2:30 pm EST on “Closing the Gaps in Air Cargo Security”. Two witnesses are currently scheduled; TSA Administrator John S. Pistole and US Customs and Border Protection Commissioner Alan D. Bersin. The focus will inevitably be on the recent ‘Toner Bombs’ incident, but it will certainly be expanded to address the general issue of air cargo screening, particularly inbound aircraft from overseas locations.

TSA Oversight

The Senate Commerce, Science and Transportation Committee will be conducting an oversight hearing looking at TSA on November 17th at 10:00 am EST. No witness list is currently available, but will almost certainly include Administrator Pistole. I suspect that this will also focus on the ‘Toner Bombs’ but could include a variety of TSA issues. I would hope that someone would ask about rail freight security implementation, and pipeline security rule development.