DHS Looking for Open Dialogue

In my last post I talked about the presentation Sue Armstrong director of the Department of Homeland Security's Infrastructure Security Compliance Division gave at the big security show (ASIS) in Dallas earlier this month. Armstrong talked about the progress DHS has made with CFATS and discussed key topics like harmonization, personnel surety, material modifications and the new online editing tool for security site plans (SSP) submissions.


The director indicated that chemical security harmonization is an ongoing process. While DHS is handling CFATS compliance, the US Coast Guard (USCG) is working on the Maritime Transportation Security Act (MTSA) and TSA is managing the Freight Rail Rule. Armstrong said that all three organizations are working together to make sure standards and mandate mesh are consistent with each other. For example, she emphasized the importance of creating a unified regulatory agenda and that there has been discussion around requiring Top Screens for MTSA sites so that risk can be measured in the same way.

Personnel Surety

Personnel surety has been a difficult and confusing issue for the industry. Background checks and screenings for terrorist are essential. Armstrong indicated that the department is still working to develop the best processes. She said that the department is talking with the industry and other agencies to come up with the most efficient way to handle authorizing personnel, vendors and visitors. Armstrong also stated that DHS may accept various credentials, as long as they can be verified.

Material Modification

Material modification is another area where Armstrong indicated that the department is interested in getting some input from the industry. She said the department understands that companies are constantly going through changes and there needs to be a process to deal with those in relation to CFATS. DHS seems to be looking for an open dialogue on handling material modifications. I believe this is just another indication of how willing DHS is to work with the chemical industry to come up with effective and workable solutions.

SPP Online Edit Tool

The SSP online editing tool is being beta tested internally according to Armstrong. Once the tool has been tested and is ready for prime time the department plans a well-announced roll out. Armstrong said they may even sponsor some Webinars on the topic.

The director also said that to remain complaint companies should remember to conduct incident investigations for all security incidents, use the online CFATS tools and watch for any changes to Appendix A of the CFATS mandate.

Armstrong pointed out that the threat of domestic terrorism in the U.S. is very real and that we need to remember the purpose of CFATS is to protect our businesses and communities. We all play a very important part in this joint effort. Mandates are not there just as an added burden to business -- they play a very real part in making us all safer.


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