Friday, February 3, 2012

Even more Information on Tomorrow’s ISCD Hearing

Yesterday the House Energy and Commerce Committee took the unusual step of publishing the written testimony of the primary witness to tomorrow’s subcommittee hearing looking as the current situation in the implementation of CFATS. Typically the written testimony is provided to Committee members and staff the day before the hearing, but the testimony is not made public before the witness appears before the committee.

The Program to Date

Much of the ten page testimony by Rand Beers, Under Secretary for National Protection and Programs Directorate is the standard DHS rehash of the CFATS program; how it was started and the steps taken to get where it is at. It does provide some new numbers about the implementation. They include:
• 4,458 facilities currently covered under CFATS
• 180 preauthorization inspections have been completed
• 53 facilities have had their SSP authorized (less than ½ of Tier 1 facilities)

• 10 authorization inspections have been completed
• 0 facilities have had their SSP approved since May 2009
• 66 Administrative Orders have been issued
Very little is said in the statement about the personnel and procedural issues that have hampered the ICSD’s efforts to more effectively move forward with the SSP implementation process. Beers blames growth problems with a new agency for some of the issues and this must certainly be a contributing cause to the problems. He does use all of the current management buzz terms (“a Division mission statement, vision statement, and statement of core values”) as if establishing these window dressing tools can possibly change the culture of an organization.

The Real Questions

Here are some of the questions that I would like to see posed to Beers and Anderson (in no particular order):
• What has been the total turnover rate for all ISCD personnel since June 2008?
• What has been the turnover rate for Chemical Facility Security Inspectors (CFSI) since June 2008?
• How many people in ISCD have been with the program since June 2008?
• How long does the hiring process take from the time a job is posted on until the new employee reports to work?
• Has the site specific pay rate problem been resolved?
• Have the travel pay problems been resolved?
• How many of the 1600 facilities that have removed their COI have replaced them with nearly identical chemicals with miniscule improvements in safety/security (for example replacing 20% Aqua Ammonia with 19% Aqua Ammonia)?

• How many of the 700 facilities that have reduced their on-site inventory by increasing the number of shipments of the COI, thereby increasing the transportation security risk?
• How many of the CFSI (or ISCD staff personnel) are qualified to assesses blast protection information?
• How many of the CFSI (or ISCD staff personnel) are qualified to conduct control system security assessments?
• How many of the CFSI (or ISCD staff personnel) are qualified to assess processes for neutralizing released chemical?
• Has ISCD signed a memorandum of understanding with ICS-CERT to receive support in the evaluation of the security protections provided to critical control systems?
• Has any ISCD facility evaluation (of any sort) included contacting local emergency response personnel to see if their support for emergency response to a successful terrorist attack had been discussed with facility management?
• Has any ISCD facility evaluation (of any sort) included contacting local law enforcement personnel that would be the first armed responders on the scene have been briefed about which areas of the plant it is unsafe to discharge a firearm?
Given access to the internal report from ISCD I’m sure that I could come up with even more biting and pertinent questions to ask this panel. But, it still doesn’t appear that the Subcommittee will be asking any serious questions tomorrow. There is none of the political posturing and grandstanding preceding this hearing that would indicate that anyone seriously cares about these problems. I challenge Chairmen Shimkus (R,IL) and his Subcommittee to prove me wrong

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