You might be thinking, “My FSP already has an FSA, so I can just change the date
and re-submit this.” Not so fast!! 33 CFR 105.310 is very clear in stating, “The FSA
must be reviewed and validated, and the FSA report must be updated each time the
FSP is submitted for re-approval or revisions.” So, the bottom line is we need to
conduct a complete FSA prior to re-submission of our FSP for approval. This is an
extremely important process so take the time to do a conscientious job because
threats are always changing.
33CFR105.300 details everything that must be considered in developing the FSA.
You must conduct a thorough on scene assessment but not limited to all of your
facility’s security systems, operations, infrastructure, threats, vulnerabilities and
weaknesses. You must also address important systems, resources and processes to
protect all of the personnel from contingencies, natural disasters, and mishaps. 33
CFR105.300 provides extensive specifics on all that must be addressed.
The FSA must also include a Risk-Based Analysis. We’ll address the RBA in next
week’s Blog. Remember to check your FSP approval date!!!