CFATS Program Basics
If you have submitted a CSAT SSP, it is highly recommended to resubmit an ASP prior to or at the point of your authorization inspection. The industry and DHS has come to realize that ASPs are the only way to comply with the site Security plan requirement. BPS just completed our 7th chemical security summit and the overwhelming consensus was ASP beats CSAT SSP.
BPS has submitted more than 100 ASPs on behalf of our clients and can help get you on the right track, particularly if you have multiple regulatory requirements (e.g. DOT, FSMA) and have multiple security plan requirements. All BPS ASPs have been approved by DHS at the first submittal.
Click here to contact us today on how we can get your sites set up with ASPs.
Keep reading to see how BPS can help you navigate the waters of submitting your Site Security Plan or Alternative Security Program and the benefits of each. We explain more of the CFATS approval process and have provided an opportunity for you to select a free whitepaper download discussing these options.
BPS can help you prepare for a successful inspection visit, moving you closer to receipt of final authorization. Do not wait, you must start preparing today.
The Department of Homeland Security has issued several regulations to attempt to keep Chemicals of Interest (COI) properly protected against security threats. The importance of compliance under this regulation is certainly multifaceted and one aspect was unfortunately illustrated to the World in 2013 when the fertilizer plant in West, Texas experienced a fire, setting off the explosive capabilities of its components and killing several people in the process. Most of those killed were first responders who rushed towards the fire, likely not knowing the quantities and capabilities of the chemicals within. If your company believes you have a COI or you have been notified by DHS that you fall under the requirements of CFATS, it is in your best interest to ensure compliance under these regulations. In some cases you may be able to change your processes to become de-regulated, however you want to be sure you follow the correct process to do so.
Below is a general flow chart of the CFATS facility approval process.
CFATS APPROVAL PROCESS
Site Identified as Potential CFATS-regulated facility
First step is to Perform a Top Screen and submit
If you have a chemical above the minimum threshold screening quantity then the first step is to perform a Top Screen and submit to DHS. If you are not sure whether the chemical and quantity qualifies, call us and we will help you make that determination.
Receive Initial Determiniation Letter
Your initial tier will be determined
You now have 90 days to conduct and submit a security vulnerability assessment - BPS can perform this for you.
DHS will Issue Final Determination Letter
Your final tier will be determined, establishing security requirements
All tiers have 120 days to complete and submit a CSAT SSP or an ASP. BPS can help you in this process.
Some facilities may receive notice of a pre-authorization inspection
This could be a sign of weaknesses in your submitted plan.
You should consider having a third party such as BPS, assist you in preparing for the pre-authorization inspection.
DHS Notifies of Authorization Inspection
You need to start preparing now. Download our "Surviving the Authorization Inspection - a Six Point Guide".
DHS Conducts Authorization Inspection
Authorization Inspections are very thorough and are generally conducted by multiple inspectors over a period of days. You need to be prepared.
Receive Final Approval
BPS is capable of taking your facility from initial notification and top screen all the way through to final approval under the regulation. BPS and teaming partner, Sage Environmental, Inc. will provide the initial consultation and top screen, if necessary. From there, the team of CVI-Certified BPS experts will assist your facility all the way through the compliance process.