This week, ADT was very excited to co-sponsor its 2nd annual Joint Chemical Security Regulatory Workshop with the Chemical Industry Council of California (CICC) in Los Angeles, California. The one-day workshop addressed various chemical security issues and regulatory challenges and offered attendees practical advice for compliance.
Speakers included leaders from industry associations, regulatory experts, local first responders, and government officials. Kicking off the event was speaker Jennifer Cannon, Compliance Section Lead (Acting), Infrastructure Security Compliance Division (ISCD), Department of Homeland Security (DHS) who provided a very informative update on the Chemical-Facility Anti-Terrorism Standards (CFATS) program.
Ms. Cannon first provided an overview of ISCD, and an explanation of its three different sections (Federal Review Center (in charge of reviewing SV, Compliance Team), and how they work together to facilitate CFATS implementation and communication. She provided some case studies that demonstrate how the various sections have worked together to solve a particular compliance challenge, such as the treatment of “articles” under the CFATS program, the CSAT “Tip Line,” and Compliance Assistance Visits.
During her presentation, she noted that ISCD recently completed an analysis of the Site Security Plan (SSP) submission and review process in an effort to identify ways to increase efficiency for certain components of CFATS compliance. Improving the SSP review process is a priority of the new ISCD Director.
As part of the analysis, ISCD clarified internal policies for ISCD review team and field personnel; developed recommendations to share with the regulated community to specifically improve SSP submissions; and streamlined the ISCD SSP review process. As a result of this analysis, ICSD will be providing more direct feedback (through conditional authorization letters, deficiency letters, or otherwise) regarding where a given facility needs to make improvements or where the security measures are insufficient.
Ms. Cannon explained that ISCD is currently addressing a number of re-determination requests, which it often resolves through Compliance Assistance Visits (CAVs). Following analysis of the request at ISCD Headquarters, Chemical Inspectors conduct an on-site CAV to verify and validate the re-determination request. Since January 2011, ISCD has completed approximately 400 CAVs and has another 173 CAVs scheduled. In 2011, ICSD resolved over 250 re-determination requests through CAVs. She also recommended accessing the CSAT Knowledge Center to review FAQ 1557 regarding re-determination requests. In the near future, DHS will post a new FAQ to discuss the re-determination process in even greater detail
Ms. Cannon also mentioned that ISCD is undertaking several new compliance initiatives including Top-Screen, Security Vulnerability Assessment (SVA), and SSP Chemical Security Assessment Tool (CSAT) enhancements. For instance, facilities seeking extensions for SVA or SSP submissions will soon be able to submit those requests in the CSAT rather than by phone or formal letter. The current SSP Webinars may also evolve to provide more targeted information based on where users are in the SSP approval process (e.g., how to edit the SSP).
ISCD has also launched a review of the Appendix A Chemical of Interest (COI) list to determine whether the COIs and COI thresholds are appropriate, and whether any COIs should be added or removed from the list.
Stay tuned for additional information from the ADT/CICC Workshop.
~ Ryan Loughin
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