DHS is feeling pretty good about the progress it has made. Here are some of the numbers Armstrong provided on the work being done by the department:
• Over 38,000 Top-Screens submitted and reviewed
• Over 6,000 Security Vulnerability Assessments submitted and reviewed
• Over 3,100 Site Security Plans submitted and in review
• Over 2,855 have been through a QA/QC review and scored
• Detailed review by Federal staff ongoing
• Over 244 Compliance Assistance Visits at facilities by DHS Chemical Inspectors -an average of 2.5 per week
• Over 150 facility-specific outreach discussions
DHS expects all final tier notifications to be completed by the end of summer. The Infrastructure Security Compliance Division (ISCD) of DHS has conducted 47 pre-authorization inspections and is now ramping up to 30 to 40 pre-authorization inspections per month. These inspections are being conducted to smooth the SSP submittal process and speed up approvals. Some facilities have already gone through this process have been able to resubmit their SSP and then received a Letter of Authorization.
Armstrong said that once the facilities receive a Letter of Authorization DHS will conduct a final inspection and the facility will either received a formal Letter of Authorization or will be given an explanation of areas that have to be corrected.
Right now ISCD has eleven regional commanders and 77 chemical inspectors. The department just began training an additional 20 chemical inspectors. Each trainee must spend a total of 14 weeks of classroom and field training for certification. They have to be knowledgeable in CFATS regulation, CSAT, physical security and hazardous materials. In additional they need to complete a number of safety classes including confined space, chemical process safety and respiratory protection.
The CFATS program seems to be gathering steam and making some real progress. I believe that is the reason the industry is eager to see the program continue in its present form and supports legislation that would do that. There is a concern that we are too far along in the process to make dramatic changes.
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