For many of our readers, who have already submitted and provided comments on the initial plan noticed in the October 1, 2010, Federal Register to address small business concerns in the private sector preparedness accreditation and certification program, commonly referred to as PS-Prep, and required by Section 901 of the Implementing Recommendations of the 9/11 Commission Act of 2007, P.L. 110-53 (“the Act”), we point your attention to a recent action taken by Senate Homeland Security and Governmental Affairs Committee Chairman Joe Lieberman, ID-Conn.

Lieberman recently released a copy of a letter that he sent to Department of Homeland Security (DHS) Secretary Janet Napolitano raising concerns about the Federal Emergency Management Agency’s (FEMA) proposed plan to improve the disaster preparedness of small businesses. Lieberman requested that his letter be treated as a response to the request for comments in FEMA Docket ID FEMA-2008-0017 (75 Fed. Reg. 60773 (October 1, 2010)) and included as part of the public record in that matter. 

In that letter, Lieberman reiterated his support for the PS-Prep program, but he also “….raised concerns about the amount of guidance that would be available to small businesses and the possibility that more oversight will be needed to ensure participants are actually meeting program standards”.

A summary of the comments in the letter submitted by Lieberman is as follows:

  1. Given that the private sector controls 85 percent of the critical infrastructure in the Nation, private sector preparedness is a necessity, not a luxury.
  2. The PS-Prep program, if properly implemented, will also raise the visibility of the importance of private sector preparedness and provide a roadmap to preparedness, benefitting businesses that choose to participate, and making America safer.
  3. In self-declaring conformity with the PS-Prep standards it is likely that many small businesses will have difficulties understanding steps necessary to be successfully prepared in conformance with the PS-Prep standards.
  4. Proper implementation of necessary steps and continual maintenance of a preparedness program may be challenging for many small businesses.
  5. Without proper support and guidance, small businesses may be left confused as to how to conform to the PS-Prep standards and will be in need of education before they can become sufficiently prepared and properly self-certify their conformance.
  6. DHS should also work to support development of tools that can be used to assist small businesses in becoming prepared.  
  7. DHS and FEMA must very actively work to raise awareness about the need for preparedness planning in order to get businesses interested in the PS-Prep program.
  8. DHS should carefully consider documentation requirements for self-declaration, and should continually oversee the self-certification process as necessary in order to protect the integrity of the program.
  9. DHS should consider whether different methods of conformance should be established for various sizes of entities that qualify as small businesses.
  10. DHS should also look for ways to reduce or eliminate the costs of third-party certifications to PS-Prep standards for small businesses, and
  11. Finally, as the initial plan evolves, it will be vitally important for DHS to carefully evaluate the effectiveness of the initial plan in order to consider what next steps should be taken to address small business concerns and requirements in the private sector preparedness and accreditation program.

Click here, to read the full press release along with the Lieberman’s full letter to (DHS) Secretary Janet Napolitano.

If you found this information valuable, please pass it along to those individuals in your organization who are responsible for business continuity, disaster preparedness, risk management and preparing for the PS-Prep program.

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