Chemical Security
To discuss how Huffmaster can help you comply with CFATS through our chemical security offerings, you can call 800.446.1515 or e-mail us.
Hot Topics
Huffmaster SecurCHEM™ Library
Useful DHS CFATS Links
Huffmaster SSP Process
Phase 1 - Site Orientation
Site Review
- Understanding your business process(es)
- Evaluating your current site security program and its application
- Review of the Security Vulnerability Assessment (SVA) for the site
Debriefing
- Provide a high level Gap Analysis which identifies the key issues to be addressed - including a focus on areas where significant changes may be required.
- Preparation for the completion of the SSP process
- Review the SSP Data Collection/Research requirements
- Assignment of Tasks/Responsibility to complete Data Collection/Research
Phase 2 - Preparation for Completing the SSP
Offsite Activities
- Huffmaster will perform a detailed Gap Analysis, including:
- Identification of deficiencies against Risk Based Performance Standards (RBPS)
- Assessment of the severity of the individual gaps
- Provide Specific Recommendations
- Targeted to specifically close identified gaps
- Integrated when possible so a single measure can support more than one RBPS
- Conduct agreed upon Data Collection/Research
- E-meetings, conference calls, and follow-up communications
- Review of Gap Analysis
- Review of Recommendations
- Discussion to achieve concurrence on recommendations
- Develop Recommendations into "Planned Measures" for the SSP
- DHS requires approved budgeting to consider "Planned"
- Key implementation milestones/timelines also required
- Review and compilation of research efforts. Phase 3 cannot start until fully complete
Phase 3 - Completion of the CSAT SSP on-line
Onsite Component
- Respond to 1200 - 1500 questions documenting the Site Security Plan
- All Data Collection/Research will be entered into the CSAT SSP Tool
- Three primary sources of information to answer questions
- Data points collected and/or researched for entry
- Site Security Measures in-place and functioning at the time of submission
- Those "Planned Measures" that have been budgeted and scheduled for implementation
Offsite Component
- Final Reviews and Error Checking (may include electronic meetings as needed)
- CSAT "Preparer" transfers the completed SSP to the "Submitter"
- Client's CSAT "Submitter" files the SSP with DHS
Phase 4 - (Optional) - Operational Support
- Implementation assistance for Planned Measures
- Development of Training and Documentation Support
- Design & Develop Audits and Exercises to evaluate and test plans
Tier 1 Facilities Notified, "On The Clock"
The Department of Homeland Security (DHS) recently began to notify facilities of their Chemical Facility Anti-Terrorism Standards (CFATS) final risk tier assignments. Chemical Security Assessment Tool (CSAT) submitters for facilities finally assigned to Tier 1 should have received an e-mail instructing them to retrieve their tiering letters from CSAT. The final tiering letters include the Chemicals of Interest (COIs) and security issues resulting in the Tier 1 assignment as well as any other COIs of concern to DHS. Upon receiving their final tiering notification, sites will have 120 days to submit their Site Security Plans (SSP).
DHS will follow up with the Tier 1 facilities regarding SSP training Webinars. These Webinars will start on May 27 and will be held every Monday and Wednesday. Each site will be allowed to have 5 attendees. Only Tier 1 facilities will be allowed to participate at this point. Facilities in subsequent tiers will have additional opportunities to participate in the training as they are notified of their final status.
There were 178 sites preliminarily assigned to Tier 1, which was reduced to 140. In addition, the SSP questions and the final version of the Risk Based Performance Standards Guidance are now available at www.dhs.gov/chemicalsecurity.
If a facility would like to request an extension for the Department's consideration, formal letters can be sent via regular mail to:
Department of Homeland Security
Chemical Security and Compliance Division
Mail Stop 8100
Washington, D.C. 20528-8100
Tier 2 Letters Scheduled for June
The Security Vulnerability Assessments (SVAs) for facilities in preliminarily risk Tier 2 are in the final review stage. Indications are DHS expects to send the Tier 2 notifications as early as June.
Some indications also point to DHS accelerating its original plan to stager each Tier by 60 days. This could mean some or all remaining Tier 3 & 4 facilites could be notified by late Summer as well.
To help you prepare, we recommend a thorough and frank review of your SVA, followed by a good read of the Risk Based Performance Standards Guidance. From a planning perspective, that review should help you develop a meaningful gap analysis.
CSAT Online Tool
DHS has officially launched the Chemical Security Assessment Tool (CSAT) for the Site Security Plan (SSP). You can access all of the information by visiting CSAT Site Security Plan page at www.dhs.gov. Only facilities that submitted a Security Vulnerability Assessment (SVA) and were subsequently notified in writing by DHS have access to CSAT to complete and submit the SSP.Unless otherwise notified by the Department, high-risk facilities have 120 days from the time of written notification to complete and submit a CSAT SSP or a Department-approved Alternative Security Program (ASP).
CVI Clearance Required for CFATS
The Site Security Plan contains Chemical-terrorism Vulnerability Information (CVI) as it discloses crucial information about the security measures implemented against potential attacks to your high risk chemical facility. CVI is the information protection system utilized to secure the SSP from inappropriate public disclosure or misuse. The Department of Homeland Security expects your representatives to safeguard CVI with extra care. DHS does offer a CVI Procedural Manual which offers the proper methods for safeguarding sensitive CVI materials. Huffmaster's chemical experts also can assist you in developing CVI training and procedures
Contact Huffmaster's chemical security experts and let us answer your questions. Call 800.446.1515 or email us. Be prepared and keep your Business Secured at a Higher Level through Huffmaster!
Disclaimer: Due to the dynamic of the nature of this program, please refer to the DHS website at www.dhs.gov for complete updates on the CFATS. Huffmaster will continue to update this page as more information becomes available.
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