Chemical Sector Security Summit Summary – Lessons Learned from Pre-Authorization Inspections (PAIs)

The Chemical Sector Security Summit included a breakout session entitled Inspections Process Lessons Learned, with speakers from both industry and the Department of Homeland Security (DHS). DHS noted that the primary lesson learned from the PAI process was that submitters need to provide more detail when completing their Site Security Plans (SSPs). Consistently, SSPs have been submitted with very little detail to explain a “Yes” or “No” answer. This is due in large part to the current design of the SSP tool. This lack of detail results in a facility not receiving proper credit for security items or processes currently in use by the site, and it ultimately leads to SSP disapproval.

The PAI is not an enforcement inspection, and DHS has enabled facilities to make changes to SSPs by unlocking the Chemical Security Assessment Tool (CSAT) and allowing sites to add additional information to the original submittal in order to update the SSP for resubmission after the PAI.