Sunday, January 1, 2012

Chemical Inspectors and ISCD Problems

I got an interesting email from a reader last week who has an interest in becoming a chemical facility security inspector (CFSI) for the CFATS program at DHS. After reading the story about the problems at ISCD he was concerned about how those problems might affect his prospects for future employment in that area. That question has specific meaning for the reader, but is also of a more generic concern for the chemical security community.

First off, let me make clear that, in my opinion, the CFATS program is going to be around for quite some time. There has been no serious talk by anyone in Congress about disbanding the program and many who want to see the program expanded to include some of the classes of facilities that are currently exempted from CFATS coverage. In fact, the political debate about the CFATS program has always been about the scope and coverage of the program, not the need for a chemical security program.

Shortage of Chemical Security Professionals

One of the weak spots in the CFATS program has always been the CFSI. This is not due to any personal or professional shortcomings of the current crop of CFSI, but rather the fact that until very recently there was no such thing as a chemical security inspector. In fact, there have been virtually no chemical security personnel at all.

Okay, there have been security personnel at chemical facilities for a long time and their number certainly increased after 9-11, but for the most part these have been standard security personnel concerned with standard security matters such as entry control, perimeter patrols, and loss prevention. The number of people that understood the unique security aspects of process chemistry, both as targets and as potential weapons, was extremely small and most were concerned about security of overseas chemical facilities owned by the major chemical companies.

In the same way there were very few people in the chemical processing industry who really understood security; locks, fences, and rent-a-cops seemed to be adequate security to most chemists and engineers.  Even then the basic necessities of those programs such as key control, clear zones and gate procedures were beyond the understanding or concern of chemical professionals.

CFSI Training Issues

Because of the lack of chemical security professionals, the bulk of the first CFSI hired and trained by ISCD were in fact security professionals; security managers, inspectors and law enforcement types. Most of them came from backgrounds in the Federal Government since this eased many of the vetting requirements.

This created a bit of a training problem for ISCD. While the training should have been concentrated on CFATS related issues (§550 restrictions, RBPS guidelines, etc) much of the focus of the Chemical Facility Security Academy had to do with chemical process and safety issues. Security personnel had to be trained in the basics of chemical process language, equipment, and chemical handling as well as the standard OSHA mandated training for personnel operating in chemical processing facilities. And there had to be at least a couple of trips to actual chemical processing facilities so that CFSI wouldn’t be totally overwhelmed by the complexity of things when they strolled into their first official inspection.

With all of that on the docket there certainly wasn’t time in the 8 week training program to include such things as the pros and cons of various security and chemical safety devices, cybersecurity fundamentals for both IT and control systems, personnel surety standards (that still don’t exist) and a whole host of other matters that would need to be evaluated in chemical security inspections.

I know that ISCD has attempted to recruit more personnel from the chemical industry to fill vacated and new CFSI positions. I have seen no figures to date on the success of that effort, but even if successful, that only complicates the training problem as people with chemical backgrounds have to be taught all of the standard security stuff about which they are clueless.

This training issue is going to plague the CFATS program for the foreseeable future. Until there is a stable stream of personnel with industry experience as chemical security professionals ISCD will be hiring people that lack significant parts of the skill sets needed to be a CFSI. One of the best places that DHS could put some chemical security grant money is to one of the schools that has an industrial chemistry program (a relatively new discipline of its own) to develop a degree program for chemical security professionals.

CFSI Requirements

In my opinion, a CFSI should first be a chemical professional. This means at least a BSc degree in chemistry or chemical engineering, perhaps industrial hygiene. Experience working in a chemical processing facility would be a plus. This background would provide the CFSI the ability to speak with and understand the engineers and chemists that run most facilities.

I don’t mean to denigrate the skill and knowledge necessary to be a security professional, but a large part of the knowledge base in that profession will not be of much use in a chemical processing environment. Besides, the §550 restrictions on specifying security requirements will get many people from a real security background in trouble in the field.

A law enforcement background will not be particularly useful in this position. The skills and training necessary to be a cop do not really apply to security (though cops will generally understand security better than chemists) and there is little need for the investigational skills associated with law enforcement. Any actual attacks or suspected attacks will be investigated by local police or the FBI not ISCD.

Restricting the hiring of CFSI to people with a chemical background will make the training problem easier for the Chemical Security Academy. They would be able to concentrate on security issues and program requirements.

So You Sill Want to be a CFSI?

So after all is said and done what does it take to become a CFSI? The short answer is you put in an application when a position vacancy is announced on I just did a search and there are no such jobs currently listed. You can set up an account on the site and have them notify you when a vacancy is announced. You’ll have to use the ‘Advanced Search’ option and I would limit the search to DHS and NPPD under the ‘Agency Search’ option.

What qualifications are necessary? Well you have to be a US Citizen and be capable of getting a Secret security clearance. Beyond that you’ll have to look at the announcement in This is still an evolving position and I expect further changes to be made in the job requirements based on the ISCD report (though I still haven’t seen the report).

What are your prospects of getting hired? That’s a good question. There are only a limited number of positions available (160 is the latest figure that I recall) and I believe that most are currently filled. I don’t see a major expansion any time soon. I don’t know how much of a turnover the Department is having (I would hope that the ISCD report touches on that, but we still haven’t seen a publicly released copy), but I don’t expect that it is real high.

Oh yes, expect to have to move. DHS has been advertising these positions as location specific for a regional office and the last listing that I saw said that they would not pay relocation expenses for new hires.

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