Roberts Law Group News

DHS Issues Revised CSAT ICR

This week, the Department of Homeland Security (DHS) issued a Notice and Request for Comments and Revision of Information Collection Request (ICR) (Notice) regarding various changes it expects to make to the Chemical Security Assessment Tool (CSAT), and specifically, the Top-Screen, Security Vulnerability Assessment (SVA), and Site Security Plan (SSP) surveys.
  • Revised Top-Screen – DHS expects to implement a revised Top-Screen which will (1) streamline the entry of information about Chemicals of Interest (COIs); (2) add new questions to assist in identifying the appropriate Security Issue; (3) include questions currently asked in CSAT SVA; and (4) utilize geospatial technology to identify a COI’s area of highest quantity. The revised Top-Screen will also allow DHS to begin using an improved tiering methodology that incorporates more relevant elements of risk. Importantly, as a result of this new tiering methodology, DHS indicates that it is considering requesting all facilities that possess COIs at or above the Appendix A Screening Threshold Quantity (STQ) to complete a new Top-Screen – even if the facility has previously completed a Top-Screen and been determined not to be high-risk.
  • Revised SVA – DHS expects to implement a revised CSAT SVA which will (1) remove duplicative questions asked in the CSAT SSP; (2) remove the attack scenarios and related questions; and (3) move several questions to the Top-Screen to support the improved tiering methodology.
  • Revised SSP – DHS expects to implement a revised CSAT SSP which will (1) remove duplicative and unnecessary questions; and (2) reorganize the SSP questions in a streamlined process.
DHS also plans to streamline the tiering process. With the revised Top-Screen, DHS anticipates greater accuracy and confidence in the initial tiering determination. While facilities will still be required to complete a SVA if deemed high-risk following review of the Top-Screen, DHS does not expect a facility’s initial determination to change following completion of the SVA.
The Notice does not provide any expected timeline for the roll out of these changes, only noting that they will be implemented following the approval of the ICR by the Office of Management and Budget (OMB). Given that the current CSAT ICR is set to expire on April 30, 2016, OMB approval (and the deployment of the CSAT changes) could come as early as Q2 2016.