Chemical Security Awareness Training Program ICR to OMB

Yesterday the Office of Management and Budget (OMB) reported that the DHS /Sector-Specific Agency Executive Management Office (SSA EMO) had submitted an Information Collection Request (ICR) renewal application for their Chemical Security Awareness Training program last Friday. According to that report the submission coincided with the publication of the required 30-day notice in the Federal Register, unfortunately the cited notice (75 FR 52768) was actually the 60-day notice that I previously reported. I have yet to see a 30-Day Notice on this ICR in the Federal Register.


This sounds like one of those administrative snafus that occur from time to time. OMB cannot complete their review of ICR application until they look at any public comments filed on the 30-day notice and that time clock cannot start until the notice is actually published in the Federal Register. Based on the history of this (and most) ICR there won’t be any public comments to review.

The current ICR for this program (1607-0009) expired on Sunday so DHS cannot require anyone to submit the personal information needed to complete the training program. Since this is a voluntary program and the user’s employer gains the potential benefit from the user completing this information (not DHS) this ICR is not much more than a legal formality.

DHS Chem Sec Training ICR

Today DHS published a 60-day notice of their intention to renew the information collection request (ICR; 1607-0009) that will allow them to continue to collect information for the administration of the Chemical Security Awareness Training Program run by the Sector Specific Agency Executive Management Office in the Office of Infrastructure Protection.
I looked at this training program a couple of years ago and found it to be a very effective training program for general security awareness training at chemical facilities. To continue to operate this on-line training program DHS will need the approval of the Office of Management and Budget (OMB) for this ICR because of the information collection activities that are inherent in the on-line training process. The current ICR will expire on October 31, 2010.
NOTE: It will not be possible to receive OMB approval for this request before the current ICR expires. There will be an additional 30-day notice that must be published in the Federal Register before the OMB can begin their approval process. I suppose that this means that DHS would have to shut down the training program until that approval is received.
No significant changes are being made in the information being submitted in this renewal application as compared to the original application submitted to OMB on July 11, 2007. In fact the only change that I saw was the listing of the total number of chemical sector employees, 850,000 (per 2009 American Chemical Council information) down from the earlier figure of 882,000 based on 2004 data from the same source.
Public comments on this ICR (there were none on the original ICR submission three years ago) may be submitted to the Federal Rulemaking Portal (docket # DHS-2010-0071). Comments need to be submitted by October 26, 2010.