Title IX of Public Law 110-53 (“Implementing Recommendations of the 9/11 Commission Act of 2007”) requires the U.S. Department of Homeland Security (DHS) to develop a voluntary private sector preparedness accreditation and certification program. DHS was charged with tasks to establish the program including:
- Designate one or more organizations to act as an accrediting body
- Designate one or more standards for assessing private sector preparedness
- Provide information and promote the business case for voluntary compliance with preparedness standards
Since the law was passed in August 2007, DHS has designated FEMA Administrator Paulison to administer the program and chair the Private Sector Preparedness Council. The council includes leadership from the Science & Technology Directorate, Office of Infrastructure Protection, and the Private Sector Office.
DHS has signed an agreement with the ANSI-ASQ National Accreditation Board (ANAB) to develop and oversee the certification process, manage the accreditation, and accredit qualified third parties to carry out the certification in accordance with the accepted procedures of the program.
ANAB has organized its “Committee of Experts” to advise ANAB on the qualifications of the “Certifying Bodies” that will accredit qualified third parties. Don Schmidt, CEO of Preparedness, LLC and Chair of the NFPA 1600 Technical Committee, is a member of the ANAB Committee of Experts along with representatives from other standards developers and private sector industry representatives. DHS has not yet formally designated any standards for assessing private sector preparedness under this law, although DHS’ Science & Technology Directorate has adopted NFPA 1600. At the October ANSI Homeland Security Standards Panel plenary meeting in Washington, officials stated they are not picking a “winner” and that all reasonable standards will be included. DHS, however, has privately informed ANAB to begin work using NFPA 1600. DHS has also published an initial draft of their “target criteria,” which will be used to select standards for assessing private sector preparedness. The “target criteria” for selecting standards includes:- A scope and/or policy statement.
- Identification and conformity with applicable legal, statutory, regulatory and other requirements.
- Objectives and strategies.
- Hazard and threat identification, risk assessment, vulnerability analysis, and impact analysis.
- Incident management, strategy, tactics, operational plans and procedures.
- Communications and warning.
- Training.
- Resources management and/or logistics.
- Assessments, audits and/or evaluation of programs.
- Program revision and process improvement including corrective actions.
These “target criteria” align almost exactly to the elements within NFPA 1600. Accordingly, we will discuss each of these criteria within upcoming newsletters.
Although this program is voluntary, businesses are watching closely. Whether they choose to seek certification or not, business leaders are evaluating their preparedness program. In the end, that’s what it’s all about—protecting employees, property, business operations, the environment, and the business entity itself.
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