Chemical Security Workshop DHS Panel: CFATS Inspections Process & Ammonium Nitrate Program Updates

We were pleased to have Carlos Vasquez, District Commander, Infrastructure Security Compliance Division (ISCD), and Paul Sanders, Inspector, ISCD, as panelists from the Department of Homeland Security (DHS) at the Joint Chemical Security Regulatory Workshop with the Chemical Industry Council of California (CICC).

Mr. Sanders opened the discussion by providing a brief overview of the Chemical Facility Anti-Terrorism Standards (CFATS) program and then a more detailed review of the CFATS Site Security Plan (SSP) approval and inspection process. He explained that the SSP is first reviewed at DHS Headquarters, and if it appears to meet the applicable RBPSs, the facility receives a Letter of Authorization and an Authorization Inspection (AI) is scheduled. If the SSP does not meet the applicable RBPSs, the facility is provided with a letter identifying deficiencies in the SSP.

After a facility receives a Letter of Authorization, Inspectors, such as Mr. Sanders, visit the facility to conduct an AI. AIs typically last about one week and involve two or more Inspectors, and facilities should be prepared to demonstrate all security elements described in the SSP. Following the AI, DHS issues the facility a Letter of Approval or, if deficiencies were identified, a notice identifying those deficiencies. The first AI was conducted during the summer of 2010, and as of June 2011, five AIs have been completed. However, as of today, no Letters of Approval have been issued.

Mr. Vasquez then provided a status update on DHS’s Ammonium Nitrate program and the recently published Ammonium Nitrate Notice of Proposed Rulemaking (NPRM), which I have previously discussed on the blog. After reviewing the basic requirements of the proposed rule, he provided a summary of DHS’s expected path forward with the program. He explained that once the NPRM comment period closes on December 1, 2011, DHS will review and respond to comments, modify the rule as appropriate, hire, train, and deploy Ammonium Nitrate Inspectors and Headquarters personnel, submit a final rule for publication, and then begin registration, enforcement and inspections.

Finally, Mr. Vasquez noted that DHS will be holding public listening sessions regarding the Ammonium Nitrate program in areas of the highest Ammonium Nitrate usage, and information about these sessions will be published in the Federal Register.

Stay tuned for additional information discussed on the Chemical Workshop panels.

~ Ryan Loughlin

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