The actual preparation and submission of the CSAT SSP, although quite time consuming, is relatively straightforward, presuming the facility information has been gathered and evaluated in advance; otherwise the submittal process could be cumbersome, requiring multiple log-in sessions to the DHS server or potential assignment of field personnel to gather and forward information to the submitter while online. Neither of these “wait until the facility receives the letter from THE DHS” options are as efficient as collecting the information in advance and having the preparer and submitter fully up-to-speed before and during the submission process.
As with the Top Screen and the CSAT SVA, the submitter should make sure to generate a printed copy of the SSP submission before sending the electronic data to the DHS — once the information has been sent, there’s no way for the facility to directly access those data without going through a special request procedure.
Figure 1 -- Systematic method: This six-step approach
The Path Forward
The clock is running for the CSAT SSP, subsequent plan approvals and related inspection audits by the DHS. This year very likely will see additional legislative action to produce a permanent (perhaps amended) CFATS rule. There’s clear evidence that lawmakers will press to strengthen, rather than weaken, requirements under CFATS. This very likely may include requiring consideration of the concept of inherent safety (www.ChemicalProcessing.com/articles/2007/158.html and http://epw.senate.gov/109th/Moore_Testimony.pdf) and removing current exemptions for facilities covered under other regulations.
We recommend performing a systematic assessment of the intent of CFATS against the actual practices and security measures of the covered facility; Figure 1 illustrates our approach. Conduct a careful analysis, then use a structured and uniform method adjusted by site-specific needs. In the final analysis, firms that develop a well-thought-out, well-supported, carefully documented, and well-implemented approach will likely achieve the intent the DHS desires.
David A. Moore is president and ceo of the AcuTech Consulting Group, Alexandria, Va. Harry M. Leith is a senior principal consultant and Lee Salamone is a senior consultant for the firm. E-mail them at email@example.com, firstname.lastname@example.org and email@example.com.