Friday, April 22, 2016

ISCD Posts CFATS Compliance Inspection Fact Sheet

Today the DHS Infrastructure Security Compliance Division (ISCD) posted a new document to their CFATS Knowledge Center that provides some limited information about the compliance inspection process.

Since compliance inspections are based upon compliance with the facility’s Site Security Plan (SSP), each facility’s compliance inspection (CI) will be slightly different. This document provides a general overview of what facilities can expect. It does make a very valid point that facilities should contact their Chemical Security Inspector or regional Compliance Case Manager for more specific details.

Two additional items of information could have (probably should have) been addressed in this document. First is the difference between compliance inspections for facilities that have completed the Expedited Approval Program (EAP) versus the standard SSP submission process. Facilities that went directly to the EAP process without undergoing the authorization or approval process may never have had a CSI inspect their facility. This will almost certainly mean that it will take more time for the CSI to look at the facility to gain a better understanding of the facility operations and how they will affect their SSP. The consequences of not successfully completing an EAP Compliance Inspection are also significantly different than for a facility that is operating under and authorized/approved SSP.

There is also a disturbing failure to mention Personnel Surety Program (PSP) compliance issues. Now this may be because ISCD is planning on explaining to facilities what to expect with the PSP portion of the CI when they approve the changes to the site security plan for the PSP. While the vast majority of the Tier I and Tier II facilities will have to go through this update process, there may be facilities that are new to the CFATS process that actually have had their PSP approved along with their SSP.

In any case it would have been beneficial to have ISCD include in this document at least a brief description of what kind of documentation facilities would have to be prepared to show compliance with each of the four PSP Options.

Still, this should be a valuable document for any facility that has an approved SSP. This combined with some frank discussions with the facility CSI should make it much easier to successfully complete a compliance inspection.

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