DHS Issues Helpful Tips for Completing a CFATS SSP

On December 10, 2010, DHS issued a new guidance document entitled “Helpful Tips for Completing a Chemical Facility Anti-Terrorism Standards (CFATS) Site Security Plan.” The tips are based on DHS’s experience with reviewing submitted SSPs, conducting pre-authorization inspections, and the general feedback and questions it has received from the regulated community.

The document specifically addresses five areas where DHS believes additional clarity would benefit the development of a SSP:

1. Appropriate Level of Detail
2. Identifying Specific “Assets” and “Systems”
3. Security Measures Appropriate to Specified Risk Levels
4. Facility-Wide v. Asset-Specific Security Measures
5. Year-Round View

DHS notes that it recognizes the SSP process is a considerable undertaking that requires a coordinated effort to develop and accurately complete. It suggests that facilities allocate sufficient resources and time for their “SSP planners, preparers, and submitters to thoroughly evaluate the processes and operations at the facility so that they can adequately answer the SSP questions….”