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The Right Stuff: ACC’s Alternate Security Program

When President Obama last month made securing America’s critical infrastructure one of his Administration’s top priorities, ACC members were already underway with the rollout of a new effort designed to streamline and improve the implementation of the nation’s primary chemical security regulatory program, the Chemical Facility Anti-Terrorism Standards (CFATS).

INFOGRAPHIC: Enhancing Chemical Security

This new effort makes use of the Alternate Security Program (ASP) and is a product of ACC’s ongoing partnership with the U.S. Department of Homeland Security (DHS).

To help promote the use of the ASP, we’re releasing a guidance document and template with detailed instructions for implementing the plan.

Taken together, the guidance and template provide valuable tools for industry and regulators as they work together to strengthen security enhancements at chemical facilities across the country, while streamlining the process for submitting and reviewing site security plans as mandated by CFATS.

Why go with an Alternate Security Program?

Chemical facilities regulated under CFATS must complete a Site Security Plan (SSP) – a cumbersome document containing a series of YES/ NO questions regarding measures to minimize the risk of a terrorist attack or other security threat. The SSP document is submitted to DHS through its Web-based Chemical Security Assessment Tool (CSAT).

While SSPs are important to onsite security personnel and federal inspectors who audit the facilities to ensure they follow clear protocols for site chemical security, ACCs Alternate Security Program and Guidance Document makes this assessment process as clear as possible for regulators and the regulated community, while eliminating the reporting of duplicate information, as CQ’s Rob Margetta observes:

[quote]Under the legislation that created CFATS, the department always had the authority it needed to accept alternatives to Site Security Plans. What it lacked was guidance for telling companies what those alternative plans should look like, and for DHS officials who would have to evaluate them.[/quote]

PJ Coyle with Chemical Facility Security News helps break down why the ASP comes out on top:

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  • Unlike the question and answer format for SSPs submitted through CSAT, ACC’s ASP document can serve as a formal site security plan that is readily accessible to DHS inspectors and chemical facility personnel. It is indeed a plan and not merely a questionnaire.
  • Security data collected through the ASP is more reliable and informative than what can be covered by a simplified Q&A document. By providing DHS with the most complete and accurate information about site security, an ASP can help the SSP approval process move along more efficiently.
  • DHS can rely on ACC’s ASP program to serve as the standard by which to evaluate chemical facility security across the U.S. As Coyle explains, “A formal document like the one prepared in this ASP will be a much better reference for facility personnel and DHS inspectors to go back to determine what the actual approved security program is for that facility; something that cannot be easily done with the current SSP tool format.”


Though the ASP has been a feature of CFATS since the rule’s inception in 2007, we agree with Coyle in that our alternative approach can better guide security enhancements for a faster, more efficient path to CFATS compliance.

The ASP has already demonstrated that it can be help eliminate the bottleneck of submitting and approving site security plans by offering a more clear and concise process. It also provides greater utility by allowing facilities to submit a document that is based on what is actually being done on site to enhance security and paints a much clearer picture for DHS inspectors.

A strengthened partnership with DHS

In addition to developing the ASP Guidance Document, ACC members continue to work in partnership with DHS to develop other tools that can help “[keep] our critical infrastructure and our communities safe and resilient,” as President Obama has requested.

DHS Assistant Secretary of Infrastructure Protection Caitlin Durkovich says every one of us has a role to play:

[quote]We are all connected to critical infrastructure and we all have a role to play in protection and resilience efforts. … Addressing these vulnerabilities in a way that recognizes current challenges and builds upon current knowledge and technology is central to our unified effort to make the Nation stronger and more secure.[/quote]

While there is more work to be done, the willingness of DHS to work with industry is a step in the right direction. Moving this type of partnership forward will be critical to the overall success of CFATS and enhancing chemical security across the nation.

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