Wednesday, November 11, 2015

ISCD Publishes CFATS Newsletter

Today the DHS Infrastructure Security Compliance Division (ISCD, the CFATS folks) posted a link to their latest CFATS Quarterly newsletter on the CFATS Knowledge Center. The newsletter is designed to provide a high-level overview of what is happening in the Chemical Facility Anti-Terrorism Standards (CFATS) program.

According to Annie Hunziker, Program Analyst with ISCD, the newsletter has been sent to “authorizers and submitters from all regulated facilities” in addition to being posted on the CFATS Knowledge Center.

This issue highlights the recent progress of the CFATS program, including approval of the CFATS Personnel Surety Program (PSP) Information Collection Request, information about the 2015 Chemical Sector Security Summit and the compliance inspection process.

Personnel Surety Program

Readers will remember that I last discussed the CFATS PSP in early October when ISCD published their Fact Sheet on the CFATS Personnel Surety Program. I told you at that time that we would be seeing a notice in the Federal register in the ‘near future’. The latest word that I have from ISCD is that the notice is still making its way through the Department’s approval process. I suspect that there is still some political pressure being exerted by industry to get some additional changes or clarifications made to the PSP process.

Compliance Inspections

The compliance inspection process is actually mentioned in a couple of the articles in the newsletter. The one of most direct interest, however, is found on the second page. Announcing that the “Compliance Inspection are in full swing” the brief article provides three suggestions for preparing for the inspection:

• Review the SSP/ASP in its entirety and ensure that there is visual evidence of each measure to demonstrate to the inspection team;
• Review the planned measures and ensure there is documentation showing the successful completion of each planned measure; and
• Ensure all personnel with CFATS duties have been trained and are fully aware of their responsibilities within the SSP/ASP.

With the GAO reporting earlier this year that there were a large number of the facilities that had undergone compliance inspections that had not completed their planned security measures, this is an area that will undoubtedly get special attention from the Chemical Security Inspectors (CSI) conducting these compliance inspections. They will expect to see extensive documentation for the reason that any planned measures are not fully in place.

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