Tuesday, June 17, 2014

CFATS Knowledge Center Update – 06-17-14

Today the folks at ISCD published two new outreach documents on the CFATS Knowledge Center web site. Both are documents that deal with Authorization Inspections; unfortunately they both have the same title – “What to Expect from a CFATS Authorization Inspection”. The CFATS Knowledge Center calls the second document: “Prepare for a CFATS Authorization Inspection Fact Sheet”.

The Fact Sheet

This is a short, two page document, which briefly outlines what the CFATS authorization inspection covers. While it is written mostly in generalities, it does provide a good overview. No one is going to ‘pass’ an authorization inspection solely based on information found in this document, but facilities would be foolish to ignore it.

What to Expect

This document is a set of presentation slides on the topic of Site Security Plan (SSP) authorization inspections. It provides more detail about how the inspection will be conducted, what information to have available, and a very short list of specific things that inspectors will be looking for.

Helpful, but…

I’m glad to see that ISCD is reaching out to help facilities through this critical portion of the SSP approval process. I don’t think, however, that either of these documents is going to provide significant assistance to the facility security team.

I’m disappointed, because I have had some interesting conversations with a number of Chemical Security Inspectors over the last couple of years and they have almost universally indicated that they have documents that they share with facilities that have been prepared by other facilities (with permission of the authors I have been vigorously assured) that provide much more detailed information about the inspection process and outline security procedures that have already been approved by DHS at other facilities.

Now I understand that ISCD has been forbidden by Congress from providing that kind of detailed guidance as to what constitutes an ‘approved practice’, but surely there is some level of detail greater than that provided in these documents that would provide actionable information without transgressing the mandate boundary.

BTW: I am sure that I have seen earlier versions of these documents before, but I can’t find them in my files. Today’s publication is not the first time that ISCD has attempted to reach out to covered facilities to try to make the authorization process easier.

NOTE to Webmaster: If you are not going to provide back copies of all of the CFATS Update fact sheets in the document center of the CFATS Knowledge Center, you might as well not list any of them. It would make the list shorter and easier to manage.

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