Monday, April 6, 2015

ISCD Publishes Latest CFATS Update – 4-2-15

Today the DHS Infrastructure Security Compliance Division published the latest monthly update on the CFATS site security plan implementation. Instead of announcing the CFATS Update on the Critical Infrastructure: Chemical Security web page they directly published the link on the CFATS Knowledge Center. I am assuming that they will get around to updating the information on the Chemical Security page.

ISCD continued with the format that they have been using for the last year. The numbers of authorized and approved facility site security plans continues to improve. In fact, if the authorization pace continues at the current pace all of the currently submitted site security will be finished by this Fall.

The number of covered facilities continues to decline at about the same pace as it has for the last year. Looking at the graph below it looks like there was a significant policy change in the CFATS program in January 2014. That is where there was a noticeable increase in the rate of facilities dropping out of the program. There is still no publicly available explanation of what is driving the decline in the number of covered facilities.

It will be interesting to see what happens in June when ISCD is supposed to publish their expedited approval facility (EAF) program for Tier 3 and Tier 4 facilities. There will be very few (probably less than 300) facilities that do not have an authorized site security plan at that point, so most of the planning and submission work will already be done. Will the remaining facilities (the ones that are not newly added or promoted Tier 1 and Tier 2 facilities) simply opt for the EAF certification process (and may be required to change their SSPs to fit those requirements) or will they decide to continue with the current process? A large part of that will depend on what the program actually looks like.

NOTE: There has been an interesting change made at the bottom of nearly every page in the chemical security web site (and perhaps other parts of DHS as well, but not TSA). They have added a Question and two radio buttons for site users to respond. The question is “Was this page helpful?” A ‘yes’ response will get a simple ‘thank you’ response. A ‘no’ will bring up another comment (This page was not helpful because the content:) four new responses:

∙ Has too little information 
∙ Has too much information 
∙ Is confusing 
∙ Is out-of-date

The response to the second question also brings a ‘thank you’ response. DHS is apparently not using cookies to track the responses because the same question is there the next time you visit the page. Once again the folks at ISCD are demonstrating that their heart is in the right place. It will be interesting to see if there are any positive results from the feedback.

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