Monthly Archives: October 2018

The Persistent Threat of Terrorism

Since 2013 there has been 159 homegrown jihadist cases in 30 states. Recent examples of homegrown terror-related incidents cited in the report include the case of a 28-year-old Ohio resident, Laith Alebbini, who was arrested Sept. 5 and charged with attempting to provide material support to ISIS. Also on Sept. 5, 26-year-old Alexander Ciccolo of Adams, Mass., was sentenced to 20 years in prison for the same crime. According to the snapshot, Ciccolo “planned to use pressure cooker explosives and firearms to target places where large numbers of people congregated, such as college cafeterias.” Ciccolo is the son of a Boston police captain.

To read more, click here.

Do I Need to Resubmit a Top-Screen?

There are still circumstances which may require your facility to resubmit a Top-Screen today, even if you have already resubmitted using CSAT 2.0. For example, a facility must report material modifications to its chemical holdings or facility operations, as these changes may alter a facility’s tier. Material modifications may include:

  • The addition or removal of COI at the STQ and concentration
  • Changes to quantity, location, or packaging of a COI as previously reported on a Top-Screen

Facilities are encouraged to report the highest expected quantity and concentration of COI they anticipate possessing over the lifecycle of their operations. By taking this approach, facilities can maintain a more efficient reporting process as they will not need to resubmit a Top-Screen when the quantity or concentration of a COI is reduced through normal operations.

Additionally, CFATS-covered facilities are required to update their Top-Screens on a regular basis, as determined by their tier:

  • A Tier 1 or Tier 2 facility must update its Top-Screen two years after its SSP is approved
  • A Tier 3 or Tier 4 facility must update its Top-Screen three years after its SSP is approved

Let us know if we can help you prepare and submit your CFATS Top Screen and prepare your facility for a Compliance Inspection.

To read about what to expect from a CFATS CI, click here.

DHS OIG Review of the USCG Oversight of the TWIC Program

The Department of Homeland Security’s Office of Inspector General performed a review of the USCG oversight of the TWIC program and found that the USCG “does not have a full understanding of the extent to which the TWIC program address security risks in the maritime environment”.

Report Findings:

  • DHS did not complete the mandated TWIC Program assessment
  • USCG needs to clarify TWIC Reader requirements for industry
  • USCG needs to improve TWIC card verification process
    • USCG completed 33,800 TWIC verifications, but only used electronic TWIC readers to verify just 2,425 cards, or 1 in 15 cards
  • USCG needs to strengthen oversight guidance on TWIC program

The report also lists four recommendation for DHS and the USCG:

  • DHS Under Secretary of Science and Technology complete the TWIC program assessment required by Public Law 114-278 to evaluate the security value of the TWIC program.
  • The USCG’s Assistant Commandant for Prevention Policy take action to more clearly define the applicable facilities that have certain dangerous cargo in bulk and which must implement the use of electronic TWIC readers as an access control measure.
  • The USCG’s Assistant Commandant for Prevention Policy improve the Coast Guard’s use of electronic TWIC card readers during annual inspections at regulated facilities by procuring new TWIC card readers.
  • The USCG’s Assistant Commandant for Prevention Policy revise and strengthen the Coast Guard TWIC Verification and Enforcement Guide.

DHS concurred with all four of the recommendations and stated that the Homeland Security Operational Analysis Center is currently conducting an assessment of the TWIC program. The estimated completion date for the DHS assessment is March 30, 2020.

To download a copy of the full report, click here.