Yesterday the DHS Infrastructure Security Compliance Division (ISCD) updated their Chemical Facility Anti-Terrorism Security (CFATS) program web site. Links were added for two fact sheets; one dealing with the compliance inspection program and one dealing with the personnel surety program (PSP).
The compliance inspection fact sheet is the same one that I wrote about last Friday. I would not have even mentioned this except for the fact that whenever the landing page is changed, I go back and check all of the links on the page to see if there were any additional changes made since the last landing page change. In this case there was; a week ago the PSP page was changed to add a link to a new fact sheet about the relatively new identifying people with terrorist ties portion of the PSP.
The first page of the two-page fact sheet is a basic description of this new portion of the PSP program. It contains no new information and everything there has been thoroughly (in my not so humble opinion) discussed here in this blog on a number of different occasions. The second page is a short list (3) of frequently asked questions (FAQ) about the program that provide a little more emphasis and one nugget of new information about the program.
In response to an implementation timing question, the fact sheet reiterates the previous information provided that ISCD, through the facility’s Chemical Security Inspector, will notify the facility when it needs to start modifying their Site Security Plan (SSP) to include implementation of the terrorist screening portion of the PSP. They emphasize this point by stating (in bold print): “Facilities should wait to be contacted by the Department before altering their SSP/ASP or attempting to submit any information for vetting.”
The fact sheet then goes on to explain that ISCD will “provide an optional supplement [emphasis added], which discusses information the Department will consider and review in order to make a determination on the facility’s ability to satisfy RPBS 12(iv)”. Hopefully, this guidance will provide the information that I had complained about being absent from the Compliance Inspection Fact Sheet. It is more than a little disappointing that a link to this ‘optional supplement’ has not been provided on the PSP web site.
The interesting nugget of information that I referred to earlier is found in the response to the second FAQ about how ISCD will be providing the notification to begin implementing the terrorist screening portion of the PSP. It states that: “Initially, DHS will be working with certain
facilities to complete this requirement during compliance inspections.”
This helps explain the confusion raised in the latest CFATS Quarterly where ISCD explained that the first compliance inspection that included Terrorist Screening Data Base (TSDB) personnel vetting was conducted on January 28th, 2016 and the first SSP change with an updated PSP was approved a little over one-month later. This was probably the same facility in both instances.
In any case, ISCD is continuing to parcel out new information about changes in their CFATS program. I hoping, however, that they are directly notifying covered facilities about these changes in their web site. The average facility security officer (for most facilities a second job for someone) does not have time to do a daily detailed perusal of the CFATS web site to ferret out these changes. Though to be fair, ISCD does a good job of annotating when web site changes are made. That is much more than I can say for other DHS agencies, like TSA for instance.