NCBF Risk Assessment (steve)


As stated in NMFS Procedural Directive 32-110-01 "Use and Implementation of Electronic Signatures" NMFS program officials must perform a qualitative risk assessment consistent with the analytic framework called out in OMB M-01-04, "E-authentication Guidance for Federal Agencies." The OMB policy, and in turn, the NMFS Procedural Directive identifies seven potential categories of impact from using e-signatures that include:

  • Inconvenience, distress, or damage to standing or reputation to any party
  • Financial loss to any party
  • Agency liability
  • Harm to agency programs or public interests
  • Unauthorized release of sensitive information
  • Personal safety
  • Civil or criminal violations


Based on the risk assessment conducted by the FIS e-signature task force, in consultation with the Pacific Region program office, the analysis focused on the following potential impacts identified on the project wiki
https://elandings.alaska.gov/confluence/display/esig/Hawaii+Non-Commercial+Bottomfish+Logbook

In order to help articulate the various pilot's appropriate levels of risk, we utilized the ThinkTank program. ThinkTank is a collaborative technology which allows for simultaneous, anonymous input of ideas and in this case, voting. Each pilot was vetting through two series of criteria to help determine the appropriate level of risk. Facilitated conversations were held to ensure that each participant had a clear understanding of each pilot, each criterion, and how exactly to vote.

In the first section each participant voted on whether or not there was a significant probability of occurrence for infraction against the pilot, this was a yes/no decision, and then what possible impact of harm might occur should an infraction occur, this was voted on a low/medium/high scale.

Next, each pilot was then voted against the OMB Assurance Levels to help gauge agreement around the group's opinion of which OMB Assurance Level the individual pilots might belong to.

There was complete agreement on the National Permit System, West Coast eLogbook, and the West Coast Fishticket Pilots, and minor disagreement to the Hawaii Noncommercial Bottom fish and the HawaiiLong-Line eLogbook pilots.

See the ThinkTank report (attached to this wiki page) for the full meeting results.