Wednesday, March 5, 2014

DHS Updates CFATS Fact Sheet

This afternoon the DHS Infrastructure Security Compliance Division (ISCD) published the latest CFATS Update with basic program numbers through February 1st.

Table 1 shows the basic numbers for January and February. The February 20th data comes from DHS written testimony at the HR 4007 hearing last month.

Feb 1st
Feb 20th
Mar 1st
Covered Facilities
Assistance Visits

Total SSPs Authorized
Authorization Inspections
Total SSPs Approved
CFATS Program Statistics

Covered Facilities

The stats for the number of covered facilities are a little surprising. Assistant Secretary Durkovich, in response to questions at last month’s hearing on HR 4007, reported that as a result of cross checking the EPA RMP list with the CFATS list ISCD had sent letters to over 3,000 facilities that had not filed Top Screens. Director Wulf reported at that same hearing that over 800 Top Screen submissions had already been received from those facilities.

I would have expected that the ‘Covered Facilities’ number would have started to increase as a result of these new submissions. Two things could be at play here. First, the Top Screen submissions were new enough that ISCD had not yet had a chance to make a preliminary finding of being at high-risk at many or any of these new facilities. Second, the rate of facilities leaving CFATS because of plant closures, inventory reductions or COI removals had accelerated so that they outweighed the increase in new facilities. I really suspect that it is probably a combination of the two.

We also need to remember that historically ISCD has only preliminarily declared about 10% of the facilities that have filed Top Screens to be at high-risk of terrorist attack. Give that figure; we would only expect about 300 of the newly identified facilities to be added to the CFATS rolls.

Site Security Plans

ISCD continues to show improvements in the total number of authorized and approved site security plans (SSPs). Table 1 shows the total number of facilities with approved and authorized SSPs.

Table 1: Totals to Date

Table 2 shows a real improvement in the rate that site security plans were authorized; an average of more than six per work day; easily the highest to date. The approved plan rate does not appear to be keeping pace. The daily average is only about 2.5, falling behind last month’s rate and far behind the best rate of almost 5 facilities per day seen in September.

Table 2: Daily Rate

I don’t understand why ISCD continues to ignore the PR potential of being able to utilize the written portion of these updates to explain the good and the bad numbers seen in these reports. I would be willing to bet that there is a reasonable explanation for the poor approval rate seen last month, but ISCD does not seem to want to publicly acknowledge the issue.

The HR 4007 hearing last week gave ISCD a pass on the whole issue of authorizations and approvals; failing to ask even the most basic questions. Continued poor approval performance is sure to finally attract the attention of the politicians in the next six months or so; probably about the time that the DHS spending bill comes to the floor. CFATS may not be able to withstand that kind of attention again.

Compliance Inspections

I still have some concerns about whether or not they are going to be able to maintain this kind of approval rate as the requirements to conduct compliance inspections continues to rise.

To date ISCD Chemical Facility Inspectors have only had to conduct 12 such inspections (as of February 20th). This will begin to be an issue early this summer as last spring’s start of significant SSP approvals means that facilities become eligible for inspection. These numbers should begin to appear on the CFATS Update in the near future.

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