Monday, October 12, 2009
I got an interesting email from a former brother at arms last week. He recently retired from the Air Force and had come across one of the many regional listings for openings for CFATS Inspectors. He provided me with a brief listing of his military background including his time as a full time inspector for the IG. He wanted to know what I thought of his chances of getting selected for the CFATS position. This is an important question, especially since the Congress is on the verge of finally approving the funding for increasing the CFATS inspection force by 168 personnel. With unemployment fast approaching 10% there is even more competition than normal for any and all job postings. Trying to figure out your chances before you go through the motions of submitting an application is just another one of those aggravations that job seekers have to deal with. I provided him with my personal thoughts by return email, but I thought this would be a good time to revisit the question of how DHS can field a professional inspector cadre. I dealt with this a little over a year ago with another ex-military man from the same region in the country. Then I wrote a series of blogs on CFATS inspectors. As we approach the season of the first formal CFATS inspections, this might be a good time to re-visit the topic. Chemical Security Inspectors As I have noted on a couple of different occasions DHS has an interesting personnel problem staffing their CFATS Inspector ranks. It is not like they can go out to the local unemployment office and ask for applicants that have experience doing security inspections at high-risk chemical plants. There isn’t much of an experienced labor pool there. So what type of experience would one want to see in job seekers if they were hiring a federal inspection force to ensure that adequate security measures were in place at high-risk chemical facilities around the country? Well a degree in Chemistry or Chemical Engineering would be nice, especially if there were also practical experience in chemical manufacturing or distribution. Fully conversant with the use of a computer the applicant should be able to use a wide variety of applications and be conversant with at least one control system programming language. A familiarity with laws and regulations would be helpful; say some experience as a paralegal or summers as a law clerk. Some hands on experience at conducting site inspections would be helpful; it takes more than a little practice to be able to walk cold into a facility and find out the things they are trying hard not to tell you without actively lying. Military experience in security operations along with some small unit raid training and unconventional weapons experience would be very helpful. Some law enforcement experience would be nice as would the ability to speak one or more foreign languages (with Spanish high on the desirable list). Finally, the best applicant would love to live out of a suit case and should live to work. It is going to be awfully hard to find any candidate with even a small number of those qualities. Training Inspectors Last spring when I was researching my blog piece on the DHS Chemical Security Academy I asked Sue Armstrong, then Director of ISCD, for some information on that program. I got a nice email back from her that included, among other things, a listing of the employment backgrounds of the inspectors that were currently in the field. Those backgrounds included: DHS Security Specialists Transportation/Inspection (Rail, Air, etc.) Immigration and Customs Enforcement Federal Protective Service Secret Service Emergency Services/First Responder State or local law enforcement HAZMAT Response Explosives/Bomb Technician Federal Air Marshal Chemistry/Chemical Processes and Manufacturing Agriculture Military (Army, Air Force, Navy, Marines, and USCG) Investigations (IG, Background, Arson, Post-Blast, Intelligence, etc.) Since DHS has been unable to get a bunch of people each with the broad background of desirable experience, they have opted for the next best thing. They have hired personnel with a wide variety of backgrounds and then trained them on the basic knowledge requirements at the Chemical Security Academy. On the Job Training I was really impressed with the foresight that DHS showed last July when they formally provided a mechanism for high-risk facilities to request a Compliance Assistance Visit. This was a timely program that would provide multiple benefits to both the visited site, but also to DHS and their inspector cadre. First facilities would be able to truly get government assistance to resolve compliance issues in a non-confrontational environment. At this point (before SSP’s are approved or in most cases even submitted) there is no down side to having an inspector visit the site. There is no danger that the inspector will find a violation that he would be forced to take action on; there can be no violations yet. Correcting a Risk-Based Performance Standard (RBPS) compliance problem before the facility SSP is submitted can only save time and money. DHS builds up a reputation in the regulated community for working with the covered facilities in a cooperative manner rather than in an adversarial relationship. This will be key in getting complete answers to future security questions. The key to an effective CFATS program (one that actively prevents terrorist attacks) is an open exchange of information (both ways) between DHS and the high-risk facilities. Finally, this program will give the academy trained inspectors a wide exposure to the vast variety of chemical facilities that will be covered by the CFATS regulations. Even chemists and chemical engineers with years of industry experience will have exposure to only a limited number of types of facilities in their career. The more facilities that each inspector can walk through and closely observe before they start their formal evaluations of site security plans this December, the better inspectors they will be. Initial Inspections Sue Armstrong, currently Acting Deputy Assistant Secretary Infrastructure Protection, told the Energy and Environment Subcommittee at the recent HR2868/HR3258 hearing that DHS will start their initial inspections of Tier 1 facilities in December. I would be willing to bet that, with the relatively small number of Tier 1 facilities and their very high-risk status, those inspections will be conducted by relatively large teams. This will be justified (properly so) by the importance of getting the inspection done quickly and completely. The large team size will also be a useful tool to get the inspectors working the inspection with a common procedure and working the inspection process bugs out in a common manner. I would bet that there will be extensive cross loading of the inspection teams from inspection to inspection to ensure that all teams are working from a similar sheet of music. This will go a long way to establishing a strong, consistent and effective inspection program.