Friday, September 24, 2010

DHS Releases CSAT SSP Edit Process User Guide

Posted by Roberts Law Group, PLLC at 4:28 PM 1 comments
The Department of Homeland Security (DHS) has released the CSAT SSP Edit Process User Guide. The manual “provides instructions to facilities for editing and resubmitting their submitted Site Security Plan (SSP) through the Chemical Security Assessment Tool (CSAT)” to make either an administrative or technical edit.

Administrative edits relate to changes pertaining to the facility’s description, contact information, local police, fire and Emergency Management Team (EMT) jurisdiction information, and employee and workshift information. Technical edits involve changes to the facility’s operations, security measures, and other non-administrative components of the SSP. Note that once DHS has approved a facility’s SSP, the facility may only make technical edits to its SSP once every 90 days.

It is important to remember that a facility’s current SSP remains in effect until the submitted edits are reviewed and approved by DHS. Further, even after a facility receives a letter from DHS authorizing/approving the SSP edits, the facility's original SSP approval date and Top-Screen re-submission deadlines do not change.

Thursday, September 2, 2010

The U.S. Government Accountability Office (GAO) Issues Pipeline Security Report

Posted by Roberts Law Group, PLLC at 2:26 PM 1 comments
In August 2010, the U.S. Government Accountability Office (GAO) issued a report reviewing the Transportation Security Administration’s (TSA’s) current efforts to address pipeline security. The GAO specifically reviewed the TSA Pipeline Security Division’s (PSD’s) risk assessment process and performance measures after observing 14 PSD inspections scheduled during the review period.

The report noted that the PSD pipeline risk assessment model could be improved by adding certain non-economic impacts such as public health and safety to its consequence component. Further, the GAO indicated that although PSD has taken steps to assess its progress in strengthening pipeline security, its ability to measure improvements is still limited as PSD is not utilizing performance measures or linking them to objectives. The GAO report recommended that TSA “establish time frames for improving risk model data, document its method for scheduling reviews, develop a plan for transmitting recommendations to operators, follow up on its recommendations, include performance measures linked to objectives in its pipeline strategy, and develop more outcome measures.”