Friday, September 5, 2008

DHS Inspections: Alternative Staffing Ideas

I have looked at a variety of issues concerning the inspections of chemical facilities that will soon be occurring across the country at more than 7,000 high-risk chemical facilities (see: “Adversarial versus Cooperative Inspections”). These blogs were inspired by a series of emails that I have received from a reader, Brandon Williams.


In one of his emails Brandon addressed one of the funding problems that DHS is having with getting this inspection force up and running. The original plan that DHS had put together for this program called for regional offices for the inspection teams. Unfortunately, the budgetary process has only provided some money for adding headcount, but no money for the regional offices. Brandon suggests that it may be time to think about virtual offices rather than physical offices.


Regional Offices


The original plan called for 10 regional offices with an Area Commander and five inspectors in each office. The current process has reprogrammed (read ‘scrounged’) funds for three. The original plan called for offices in:


  • Boston
  • Newark (being funded)
  • Philadelphia (being funded)
  • Chicago
  • St. Louis
  • Atlanta
  • Houston (being funded)
  • Seattle
  • Los Angeles
  • Denver

I would assume that there would be an additional compliment of administrative personnel, probably including a receptionist and office manager. The physical plant would include cubicles, office equipment and meeting rooms. Most importantly there would be secure communications and information storage equipment to protect the Chemical-terrorism Vulnerability Information (CVI) and intelligence information that the inspection teams would need to complete their inspections.


I believe that part of the reason for lack of funding for the regional offices is that both the Administration and the Democratic Congressional Leadership are still looking at CFATS as a temporary program. The Section 550 authorization for CFATS expires next year. So far, there seems to be no real effort beyond Chairman Thompson’s (D, MS) House Homeland Security Committee to continue the CFATS authorization past that expiration.


Virtual Offices


Brandon noted in one of his emails that:


  • “With contact centers such as the Fusion Center(s) and the Federal Center in Denver where DHS already has connectivity and a presence to serve as hubs (or telework centers) where any more detailed computer access or more-secure comm needs can be achieved, why not consider alternatives that would still provide a presence in the central/west coast without the additional overhead of a formal facility?”

Most of the information that these inspectors will be dealing with will be unclassified CVI data. The CVI Procedures Manual does not require the use of a secure line to electronically transmit this data from one location to another (a good thing since very few high-risk chemical facilities would have access to such communications), they simply suggest that such information be ‘encrypted’ if it is not sent via a secure internet connection. There are even provisions for sending this information by Fax.


DHS has set up secure internet protocols for the CSAT submissions of Top Screens, SVAs and SSPs. There is no reason that they could not set up a similar portal for inspection reports and the like. Reporting procedures need to be streamlined to allow for the maximum facility contact time. An inspection reporting web-portal in CSAT seems to be a logical way of accomplishing that.


The only real reason for establishing these regional offices would be for administrative control purposes; eyeball-to-eyeball contact between the Area Commander and the inspectors. That does not have to be done on home-turf. As Brandon pointed out there are a very large number of federal facilities that have conference rooms that could be used for that purpose.


In short, if it becomes a question of establishing a regional office somewhere, or adding more inspectors, I know where I would suggest that the money be spent. More eyes in the field are going to do more to improve chemical facility security than will any number of office managers. I would not be surprised if DHS could not get two or more five-man inspection teams for the cost of a single office. This is truly a no brainer, put more people in the field.

1 comment:

Anonymous said...

To whom it may concern:

I find your comments very accurate and would agree with many of your suggestions.  There is a great opportunity here to truly get on-board with the telework philosophy that is sorely needed throughout these economical energy challenges.

I would like to comment on where I believe additional successes may easily be found; the key of course is the partnerships with State, local and private sector chemical partners, after 30 years in this field, go for the low hanging fruit.  It is my opinion that the nucleous is to build upon the existing successes within the EPCRA, SARA Title III, RCRA, CERCLA programs and not to re-invent the wheel.  True, CFATS is about security; but lets not forget why this is so important - it's about the chemicals involved (Tier I, Tier II, TIHs, EHSs, etc.).  In many parts of our country we still only have a fledgling capability to respond to a chemical spill, let alone launch a defensive posture involving a terrorist imployed event against a chemical facility. Law enforcement has bought into the CBRNE approach to response, but not into the hazmat response or their place in a hazmat event; the two must be addressed together.  Planning, training and exercising involving industrial chemical facility releases involving accident and/or mishap, natural disaster and of course man-made events must all be exercised on a regular basis.  

Finally, to close out my initial comments and ramblings, the lack of funding for planning, training and exercising on Federal, State, local and private sector's part is only an excuse in my opinion.  Are we really not going to respond to an emergent event because of a lack of funding?  The people who rely on our prevention, mitigation and response efforts pay our salaries.  How dare anyone say that we would not respond and even consider losing the peoples trust in their public servants.

What say you?

Doc Fungus

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