The neverending campaigns, primaries, debates, interviews, parodies, commercials and elections are blessedly over. The electorate (and not the courts) has spoken and we will have a new party in the White House and a large number of new legislators taking office in January. If form holds true, we will most likely have a new Secretary of the Department of Homeland Security.
The issues facing him or her will be numerous and of ever increasing importance to maintaining the state of preparedness for the United States. Identifying and preventing terrorist acts at home and abroad, securing our ports and airports and quite possibly restructuring of DHS including FEMA will be foremost on the list of activities.
Somewhere amid the many priorities facing the new administration will be how to move forward with the implementation of the “Private Sector Preparedness Act” (PL 110-53 Title IX Section 524). This sct requires the Secretary of the Department of Homeland Security to designate an officer to implement the voluntary private sector preparedness accreditation and certification program.
The first set of actions was accomplished by having FEMA’s designee being appointed to head the initiative. Following this designation, the next deadlines in the Act were clearly spelled out, “Not later than 210 days after the date of enactment of the Implementing Recommendations of the 9/11 Commission Act of 2007 the designated officer shall develop and promote a program to certify the preparedness of private sector entities that voluntarily choose to seek certification under the program; and.. Implement the program.”
Clearly this has taken substantially longer than anticipated. After 16 months, the major accomplishment was that the designated officer named ANSI-ANAB (American National Standards Institute – ASQ National Accreditation Board) as the sole sourced appointee to establish and oversee the development and implementation of the accreditation and certification requirements for the Voluntary Private Sector Preparedness Accreditation and Certification Program. While ANSI-ANAB has diligently pursued its charter to establish the criteria for “Certification Bodies,” those who will be chartered with the “audit” roles and grant certification, their ability to complete their mission on time is in jeopardy.
The ANSI-ANAB committee of experts who are representing various industry, government, standards development organizations and training organizations has met twice and has an imposed deadline of Feb. 14, 2008 to create the core competencies that must be demonstrated by those who will be accredited to perform certification audits. Clearly the need for certification bodies to demonstrate proficiency in emergency/disaster management and business continuity is crucial to establishing credibility in the private sector community. Without having experienced auditors who are trained and experienced in the BCM disciplines the value of the evaluation and accreditation process will be suspect. Therefore it is important that there be clearly defined requirements so that companies will recognize the value of the certification.
But even with well defined and articulated requirements and a process for accrediting certification bodies, there will be little progress made in this effort unless DHS can “ begin supporting the development and updating, as necessary, of voluntary preparedness standards through appropriate organizations that coordinate or facilitate the development and use of voluntary consensus standards and voluntary consensus standards development organizations.” Even the ANSI-ANAB deadline to report out on the certification body requirements is dependent on the identification of the standard(s) by which organizations can be measured. While there has been considerable effort, there has been little information sharing coming from DHS.
On Oct. 2, 2008 ANSI-HSSP held its Seventh Plenary Meeting, in Washington, DC. During this meeting DHS revealed a “target” document that outlined the functional requirements for a voluntary preparedness standard. When asked by attendees if DHS was creating a standard, DHS was quick to point out this document was not in itself a standard, but was designed to be “consistent with the direction in Title IX of Public Law 110-53 for consultation on the selection of standards to be adopted into the Voluntary Private Sector Preparedness Program, the Department of Homeland Security (DHS), by the publication of this notice, is initiating discussion on the proposed target criteria for voluntary preparedness standards with its Critical infrastructure and Key Resources (CIKR) partners and other interested private sector industries, businesses, and stakeholders.”
Clearly this was a much needed attempt by DHS to elicit comments from interested organizations, standards development organizations, public entities and private corporations. The comments that would be received from these interested parties would then be incorporated into the process of designating a standard or standards that would become the criteria for certification. The process would ideally result in taking the requirements and performing a cross walk against existing standards to ensure a process that would acknowledge established programs.
There has been a great deal of talk by representatives of DHS that points to an eleventh hour attempt to complete the process of designating a standard or standards or actually creating some hybrid form, before the end of the 2008. With the standards around the world in a great state of flux, patience and thoroughness should be the order of the day.
Al Berman is a CBCP, MBCI, a NFPA committee member, a member of the NY City Partnership for Security and Risk Management, and the co-chair for the Alfred P. Sloan Foundation. He currently serves as executive director of DRI International. He can be reached at alberman@drii.org.
"Appeared in DRJ's Winter 2009 Issue"
