Action Plan: Enhancing Federal Operational Coordination
Coordinating EO Implementation Activities
The EO implementation effort has demonstrated the value of close coordination between Federal departments and agencies with regulatory responsibilities. Similarly, the need for coordination at the regional level and local levels is critical to improving chemical facility safety and security. The Working Group continues to coordinate the activities required to meet this objective. To ensure the sustainability of the EO implementation efforts and avoid creating overlapping structures, the Working Group will work with existing coordinating mechanisms, specifically the NRT, the RRT, and the Government and Sector Coordinating Councils (GCC/SCC) as necessary.
Short Term (within 1 year of this report) Plan:
- Establish a Chemical Facility Safety and Security Executive Committee and a National Working Group that will (1) be responsible for Federal interagency coordination and collaboration on the implementation of the actions identified in this report, (2) maintain visibility on the progress being made in the Regional Working Group, and (3) provide assistance and support as needed.
- Establish Chemical Facility Safety and Security Regional Working Groups that will be responsible for establishing and implementing a structure for regular briefings and feedback from all stakeholders regarding the actions identified in this report.
- Ensure that Federal agencies engaged in the implementation actions are familiar with EO 12898 Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations within 6 months of the release of this report.
Establishing Standard Operating Procedures (SOPs) for Federal Coordination at the National and Regional Levels
Coordination among Federal agencies needs to be bolstered at the national and regional levels to ensure continued progress toward implementation of the activities identified in this report. Coordination is already occurring and has improved chemical facility safety and security management across the Federal sector; however, it must be systematic and institutionalized. The EO called for the Working Group to create comprehensive and integrated SOPs for a unified Federal approach for identifying and responding to risks in chemical facilities.
Medium Term (prior to the end of FY2016) Plan:
- Disseminate the templates of the SOPs developed from the New York-New Jersey Pilot and require that each Regional Response Team (RRT) develop SOPs tailored to their respective regions. Templates will be distributed within 90 days of this report and the remaining RRTs will develop their SOPs within 1 year.
- Expand the cross-training of field staff that is currently underway for DHS and United States Coast Guard (USCG) to include other regulatory programs.
Training Federal Chemical Facility Safety and Security Regulatory Programs Field Personnel
Federal regulatory programs benefit when field personnel understand the full complement of regulatory programs that impact facilities. A coordinated cross-training program can provide field staff with the knowledge and necessary background to observe potential unaddressed regulatory issues at facilities and make referrals to other regulatory agencies. Awareness of key items of concern for partner regulatory programs increases opportunities to identify issues proactively (i.e., by looking for the top issues/violations that concern other programs). Awareness also serves as a mechanism to develop and foster relationships among field personnel from different agencies to facilitate information sharing and functional coordination.
Medium Term (prior to the end of FY2016)
- Develop an interagency resource to describe Federal programs relevant to chemical facility safety and security and include key items each program considers its most frequent or critical violations.
- Expand the cross training of field staff that is currently underway for CFATs and MTSA to include other regulatory programs