Question: How may a corporation with multiple facilities regulated under CFATS request the corporate approach and what benefits does this provide the corporation?
Answer: The Corporate Approach is used to help corporations with multiple CFATS facilities better organize for CFATS regulated activity in order to make the activity more efficient. Many corporations have security measures which are governed by the corporation rather than the facility and thus employed across multiple CFATS regulated facilities within the corporation. These may include items such as personnel surety, cybersecurity, and security policies and procedures. DHS Inspectors can document these corporate-based measures during an Authorization Inspection. This documentation may be included in the other facility case files within the same corporation and be referenced by future inspection teams. Evaluating the corporate-wide security measures can allow the inspection teams to focus on facility-specific measures while on site, thereby reducing the amount of time required for each Authorization Inspection. Each Authorization Inspection will still include a validation that the corporate measures are being employed at the facility level, but will not require an in-depth review of each measure.
In addition, corporations with numerous CFATS covered facilities may be able to work with DHS to coordinate inspection schedules. This may allow for a staggered inspection schedule, staggered Site Security Plan/Alternative Security Program SSP/ASP submissions and/or multiple inspections to take place in one week, which may provide efficiencies for both DHS and the corporation.
To begin the process of requesting a corporate approach, a corporation with two or more CFATS regulated facilities should reach out to an Inspector or Regional Director in the area where the facility’s corporate headquarters is located. Another option is to contact the Compliance Case Manager responsible for the region where the majority of your facilities are located. If you do not have this information, you can reach out to the CFATS help desk at 866-323-2957 or [email protected] to request information on your local contacts.
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