Chemical Facility Anti-Terrorism Standards Personnel Surety Program

ACC appreciates this opportunity to comment on the Department of Homeland Security (DHS) Information Collection Request (ICR) regarding the Chemical Facility Anti-Terrorism Standards (CFATS) Personnel Surety Program (PSP). ACC believes this ICR is necessary to ensure that all facility personnel and visitors requiring access to restricted areas and critical assets of high-risk chemical facilities do not present a terrorism threat to the facility, its workers or to the surrounding community. In addition, this ICR represents significant progress towards our collective goal of providing a program that ensures the security of high-risk chemical facilities while minimizing the burden to the regulated community. Attached are specific comments that highlights the progrssion of progress with PSP since it's initial release in 2009. In addition ACC offers the following recommendations that will further enhance the PSP proposal in a manner that meets DHS's goals for personnel surety, improves the utility of the information collected while minimizing burdens on regulated industry: •DHS should clarify the parameters of acceptable technology that is periodically updated using the Cancelled Card List (CCL) to vet personnel that hold TWIC Cards. Facilities could greatly benefit by using the CCL; •DHS should provide a voluntary option for Tier 3 and Tier 4 facilities to submit PII on their affected individuals to DHS for TSDB vetting; •DHS should improve the transparency of the vetting process and ensure that affected individuals are cleared prior to be granted access to restricted areas and critical assets and develop a protocol for notifying the facility in the event of a positive match; •DHS should expand the TWIC program to the CFATS community; •DHS should establish a secure website for affected individuals to submit their Personally Identifiable Information (PII) directly to DHS.

Filed on regulations.gov — full text not in the inline record.