Saturday, September 14, 2013


Yesterday the folks at DHS Infrastructure Security Compliance Division published the September update for the status of site security plans (SSPs) in the Chemical Facility Anti-Terrorism Standards program as of September 1st. They note a slight drop (23) in the number of facilities covered under the program to just 4,275 facilities. This is out of the more than 44,000 facilities that have submitted a Top Screen showing that they had significant quantities of one or more chemicals of interest (COI) on site.

The table below shows the total number of authorized and approved SSPs. ISCD continues to increase the number of facilities in each category. The initial data is the number of authorizations and approvals completed before the start of the monthly reporting program; it is a guestimate since the initial CFATS Status Report was not clear on the starting point of the data. 

The second table shows the daily rate of authorizations and approvals. Earlier versions of this report did not always report the numbers as of the first of the month. This chart shows the number of authorizations and approvals in the reported period divided by the number of days in that period. Again it is possible that the graphed data for April is off because the data starting point of the initial CFATS Status Report was not clear.

As an outsider it is hard to judge the efficacy of the SSP authorization and approval process. It is easy to say that the process is not proceeding fast enough when you look at the total number of facilities yet to have their SSP approved. This  is, however, a very complex process that cannot be rushed without compromising the integrity of the assessments being made.

I dealt with the issue of SSP backlogs earlier this year and would like to suggest that Reader’s go back and look at that post as I provided a suggestion for a way out of this dilemma that I think deserves discussion. We need to solve this problem not just complain about it.

BTW: None of the ‘approved’ SSPs actually have a final approval as there is still no current method for facilities to vet their personnel against the Terrorism Screening Database (TSDB) and this is required for Risk Based Performance Standard #12. We are still waiting for the final approval of the CFATS Personnel Surety Program.

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