Narratives of Change Since Withdrawn ICR

Narrative of Changes from Withdrawn
CFATS Personnel Surety Program Information Collection Request
Collection Title:
OMB Control No.:
Collection Instrument(s):

CFATS Personnel Surety Program
1670-NEW
Background Check to Identify Affected Individuals With Terrorist
Ties

In June of 2011, the Department submitted an Information Collection Request about the CFATS
Personnel Surety Program to OMB.
See http://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201105-1670-002. In July of
2012, the Department withdrew the CFATS Personnel Surety Program ICR because the
Department’s thinking about the CFATS Personnel Surety Program had evolved since the ICR
was initially submitted to OMB.
When compared to the Department’s last public burden estimates in the June 2011 ICR, the new
ICR incorporates several changes. Many of the changes address issues raised by stakeholders
during the period of dialogue after the ICR was withdrawn by the Department in July of 2012 but
before the publication of the 60-day notice in March of 2013. The changes are:
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Addition of Option 3 (electronic verification and validation of an affected individual’s
TWIC)
Limitation to Tier 1 and Tier 2
Reduction in the number of high-risk chemical facilities to align with current facility
estimates rather than continued reliance on outdated expert opinion
Change in the distribution of the 16 model facility types to align with actual data rather
than continued reliance on outdated expert opinion
Inclusion of a specific burden estimate related to unescorted visitors
Addition of a capital cost estimate due to Option 3
A commitment to provide certain users of the CSAT Personnel Surety application the
ability to submit records of affected individuals via a web service
The inclusion of several illustrative examples about how high risk chemical facilitates or
designees are likely to consolidate RBPS 12(iv) processing, while performing routine
background check activities related to those required by RBPS 12(i)-(iii)
Discussion about individuals that will require access to restricted areas or critical assets
without visitor escorts or without the background checks listed in RBPS 12 under
exceptional circumstances
Discussion of alternatives considered but ultimately not selected by the Department

The burden estimate in this ICR, when compared to the June 2011 ICR burden estimate:
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Decreases the estimated number of respondents whose information will be submitted
annually to the Department from 1,303,700 to 195,000; and
Decreases the estimated total annual cost to the public from $29,704,000 to $4,844,000.