Thursday, July 9, 2015

ISCD Publishes CFATS Update for July 2015

Today the folks at DHS Infrastructure Security Compliance Division (ISCD) published the latest CFATS Fact Sheet. The Fact Sheet provides some numbers associated with the implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) program. The numbers show a continued improvement in the number of site security plans (SSP) that have been authorized and approved. The table below provides a summary of the data from this update and the previous month’s update.

June 2015
July 2015
Covered Facilities
SSP Authorized
SSP Approved

Actually the July data only reflects one half of a month since the effective date for the June report was June 15th and the July report is dated July 1st. However, if we look at the per-day rate change we can see that the authorization rate is much lower than normal (1.4 per day vs about 6.0 per day this year). This almost certainly reflects the fact that the back log of facilities with submitted SSP’s has been practically eliminated. The daily SSP approval rate is just about what we have been seeing this year.

As I noted in an earlier post we are about to see a major change in the way that facility SSPs will be approved for the Tier 3 and Tier 4 facilities that not make up the bulk of the unapproved SSPs. Starting on July 16th Tier 3 and Tier 4 facilities (whether or not they already have an approved site security plan) may begin to submit EAF SSP documentation. While we are waiting to see exactly how ISCD will be accepting that information (I suspect a new on-line EAF tool in the Chemical Security Assessment Tool – CSAT) I expect that the submission process will sufficiently streamlined that we should be seeing submissions in relatively large numbers early in the process. Within 100 days of a facility submission DHS is required to take action on the submission (approval/disapproval) or they SSPs automatically become approved.

All in all, I think that we are going to see a major change in the SSP implementation reporting next month. Hopefully, that will include reporting on the reasons behind the decline in the number of covered facilities as well as data on the compliance inspections that have been done on facilities with approved SSPs.

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