Monday, December 1, 2014

DHS Publishes CFATS Update for November

This afternoon the DHS Infrastructure Security Compliance Division (ISCD) published the latest update on the status of the CFATS site security plans (SSPs). It is unusual for ISCD to publish this data so quickly (especially after a holiday), but I suspect that they are trying to influence the Senate leadership in bringing HR 4007 to the floor for consideration.

As we have seen over the last year and a half now, ISCD is continuing to show improvement in the number of facilities with authorized SSPs and approved SSPs. Unfortunately, ISCD has also been conducting compliance inspections at the facilities with approved SSPs for over a year now, but has failed to provide any information on the results from those compliance inspections. This is the next measure of CFATS program progress that Congress should be asking about.

Below are my updates of the graphs that I have been publishing for a year documenting the progress that has been made on the SSP authorization and approval process.

After a small one month increase in the number of covered facilities, ISCD is again reporting a decline in the number of facilities covered under the CFATS program. Facilities can drop out of the program for number of legitimate reasons, the reduction or elimination of inventories of DHS chemicals of interest or facilities going out of business. Programatically, ISCD owes us an explanation for the reasons for the decrease in the number of covered facilities, but has thus far ignored calls to provide that information.

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