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.
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 nations 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.
US Code:
6
USC Part 27 Name of Law: Chemical Facilities Anti-Terrorism
Standard
PL:
Pub.L. 109 - 295 550 Name of Law: FY07 DHS Appropriations
Bill
US Code: 6 USC Part 27 Name of Law: Chemical
Facility Anti-Terrorism Standard
PL: Pub.L. 109 - 295 550 Name of Law: FY07 DHS Appropriations
Bill
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