In October the Department of Homeland Security (DHS) announced a new editing feature on the Chemical Security Assessment Tool (CSAT). It allows companies to go online to get the most recently submitted version of their SSP and make edits that then can be resubmitted to the department. Facilities can make administrative or technical changes.
An administrative change is pretty basic. It involves the following types of changes:
• Contact information
• Facility description
• Employee and work shift information
Facilities can make administrative changes as often as they need or want to. There is no limit on the number of edits.
A technical change is a little more complicated. Technical changes include the following:
• Operational information and procedures
• Security programs and processes
Facilities can only make technical edits to the SSP every 90 days.
DHS offers detailed instructions on using the editing tool. One thing that the department has really emphasized is that making an edit to the SSP does not affect any CFATS deadlines. Your facility is still subject to the same deadlines that existed before the edit was made. Editing the SSP does not reset or roll back the clock.
Since a technical edit can only be requested every 90 days it is important for facilities to be careful and accurate about the information they are submitting. Look at the changes you are making very carefully and make sure that your processes and programs are in place and meeting your goals before you make a change to the SSP.
Most chemical facilities falling under the CFATS mandate received the news of an online editing with relief. As chemical facilities and the DHS wade through this standards process there have been and will be some inevitable changes. This new tool makes it much easier for a company to update information or provide additional information as needed. It also should be very useful over the long run. As CFATS becomes more established and we settle into the process it will be a very practical tool for both the DHS and the industry to track any changes.