Tier 2 Letters Released; SSP's requiring more time, resources

DHS recently announced the release of Tier 2 notification letters starting the 120 day countdown to complete the SSP using the RBPS for each Chemical of Interest.

Preliminary findings from our Tier 1 clients reveal a substantial number of complexities they did not anticipate in completing their SSP's - especially when compared with their SVA's. We also received several last minute calls from new Tier 1 clients who realized the strain on time and manpower, and their lack of advanced subject matter expertise.

If you haven't taken the time to read through the entire Risk Based Performance Standards and SSP Guidance documents (CSAT SSP Questions, CSAT SSP Instruction Manual, CSAT SSP Screen Shots), and haven't yet explored your online SSP itself, we strongly urge you to do so.

If you anticipate being categorized as a Tier 3 or Tier 4 facility, please take advantage of the opportunity to review the above documents - before your response time begins - because the process will require the same amount of time despite having fewer chemicals or smaller quantities at your facilities.

The SSP entails a very labor intensive process for all tiering levels (DHS estimates 200 hours to complete for medium-sized facilities).  Have you considered whether you will have the time and/or security expertise to develop and submit the SSP for each of your high risk facilities?  Having "guards, gates and guns" is not enough to make you compliant with the Chemical Facility Anti-Terrorism Standards (CFATS) requirements.

As an active participant in CFATS, Huffmaster is available to assist you with developing the appropriate responses to the 1200-1500 SSP questions. The responses you give in your SSP will be those against which the adequacy of your plan is measured and, against which the company's facility will be audited.

For more information about the CSAT Site Security Plan, you can visit the DHS website. You also can visit Huffmaster's CFATS Compliance page for the latest CFATS updates. Our representatives also are available to discuss your immediate needs at 800.446.1515.

 

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