Thursday, November 14, 2013

CSI Dissatisfaction

I have been hearing some rumblings that there may be some increasing tensions between the CFATS chemical security inspectors (I hate this acronym, please change the name to chemical facility security inspectors) and the Infrastructure Security Compliance Division (ISCD) headquarters. It seems that there is at least an impression that HQ is increasingly overriding SSP approval recommendations made by CSI.

Now we have to remember that there will always be a little bit of a disconnect between field operatives and headquarters personnel in any organization. While the over-all mission of the organization may be the same, the focus of field personnel and upper management will always be somewhat different. I have seen this in every organization that I have worked in in almost 30 years in industry and 15 years in the military (oops that doesn’t add up as I can’t be more than about 40 years old).

The complaint is also more than a little surprising since there is a great deal of pressure on the management of ISCD to get the SSP authorization and approval process completed. Congress, the regulated community and the security press all want to see the approval process completed in a much shorter period than the current authorization and approval rate would seem to indicate is possible. One would tend to think that the ISCD HQ would be more likely to over-ride field organizations in the direction of approval rather than disapproval.

Now I have talked to Director Wulf and he appears to be focused on expeditiously, but appropriately moving the authorization process forward. And the general comments I am hearing from the field seem to indicate that the CSI realize this and support his efforts. The complaints have more to do with the involvement of the intermediate leadership in that process.

From where I sit, I cannot tell if there really is a problem yet. Individual complaints and observations may just be colored by isolated personal observations and interactions and may not reflect overall organizations issues. But, ISCD managers need to remember that the perceptions of the folks at the operational end of the organization will affect the way that they do their jobs, even if those perceptions do not reflect reality.

David Wulf took over control of ISCD when there was a serious disconnect, even outright conflict, between the field operations folks and HQ. He and his staff have worked hard to correct many of the problems that were the source of that conflict. But, they need to remember that, amongst all of the other problems they deal with on an ongoing basis, they cannot consider the communications with the filed a solved issue. This is something that will require an ongoing focus and continued effort.

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