The emergency request is approved, as revised to correct errors in the initial submission. Since CSAT registration began prior to OMB approval, the agency should report this as a PRA violation in next year's Information Collection Budget.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
12/31/2007
6 Months From Approved
140,800
0
0
1,277,200
0
0
0
0
0
In order to comply with the regulations set forth in the FY07 DHS Appropriations Bill, information must be collected from chemical facility owners and operators. The CSAT system will enable all owners and operators the ability to create a user account, answer questions related to chemical manufacturing, storage and other pertinent facility questions. The user registration portion of the system was put into production April 6, 2007. The Top-Screen section is scheduled to be in production on June 8, 2007. An email address and phone number will be available for those who need technical consultation. If owners do not comply by the congressionally mandated dates, a fine of $25,000 per day will incur.
Section 550 of P.L. 109-295 (Section 550) directed the Department of Homeland Security to promulgate and enforce regulations to enhance the security of the nationÂs high risk chemical facilities. On April 9, 2007, the Department issued an Interim Final Rule, implementing this statutory mandate. (72 FR 17688). Section 550 requires a risk-based approach to security. To facilitate this approach, the Department is employing a risk assessment methodology known as the Chemical Security Assessment Tool (CSAT). The CSAT is a series of six public web-based computer applications: User Registration, Top-Screen, Security Vulnerability Assessment, Site Security Plan, Personnel Surety, and Chemical-terrorism Vulnerability Information Authorization. Each of these computer applications constitutes a collection. In addition, there is also a CSAT Helpdesk, which constitutes another collection.
Section 550 required the Department to promulgate interim final regulations no later than six months from the date of enactment of the statute (i.e., April 4, 2007). Due to that short statutory deadline, the CSAT applications are in different development stages. In early March, when DHS submitted the IFR to OMB, only two of the collections (User Registration and Top-Screen) were ready for PRA review. As of mid-May, four of the collections (Helpdesk, User Registration, Top-Screen, and Chemical-terrorism Vulnerability Information Authorization) are sufficiently complete for PRA review. The remaining three applications (Security Vulnerability Assessment, Site Security Plan, and Personnel Surety) are either in the early stages of development or still working through the requirements definition stage of the IT development lifecycle. The Top Screen is scheduled to be moved to production on June 8, 2007.
Scope: This submission includes the CSAT Helpdesk collection and three of the six CSAT applications. The Department is requesting that OMB approve these collections no later than June 7, 2007. DHS will present the remaining three collections to OMB for approval at a later date.
New regulations gave DHS the authority and responsibility to collect information from all chemical facilities across the country. DHS must understand how each facility operates so that the facility can be placed into a tier. Once the tier has been established, DHS can determine if the appropriate security and risk mitigation documentation is appropriate. The same 40,000 individuals will be completing the User Registration and Top-Screen portions of the system. The program estimates that there will be a percentage of users who require technical consultation through the help desk function. Additionally it is also imperative that individuals understand the new document classification of Counter-terrorism Vulnerability Information (CVI). Thus the Department created a CVI training course and Non-Disclosure Agreement document. It was determined by DHS privacy officers that SORNS were not necessary for CVI or Helpdesk portions of the system. There will be a revised PIA that will cover much of the new and future development within the CSAT program.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form DHS Form Number Pe CSAT CVI Training
PIA - CSAT Update - Final 5-29-07.pdf
SORN GITAARS CSAT.doc
CSAT CVI Training