Wednesday, October 7, 2015

CFATS Fact Sheet – October 2015

I have been kind of surprised that the DHS Infrastructure Security Compliance Division (ISCD) has not yet published their CFATS Fact Sheet for October. I had a little time on my hands earlier today, so I went searching and I found it. I’m not sure if ISCD had intended on releasing this yet, so take all of the comments that follow with a grain of salt.

The table below compares the data from the October Fact Sheet with the September Fact Sheet that I discussed last month.

Sept 2015
Oct 2015
Covered Facilities
Authorized SSP
Approved SSP
Compliance  Inspection


The month-to-month trends for the two SSP categories look good; they continue to show improvement. And ISCD has finally started to list the number of compliance inspections that it has completed. As expected we have a long way to go to get all of the compliance inspections done, but at least we can now see how much progress is being made.

It is interesting to see that the number of covered facilities continues to drop. Unfortunately, that is still a data point that can be interpreted in a number of different ways because of the lack of substance in the information provided. It could be a good thing if facilities are finding substitute chemicals that do not present the same terrorist target risk as the DHS chemicals of interest that are being replaced. Or it could be a sign of impending doom as more and more chemical facilities go out of business due to the cost of implementing CFATS site security plans. Or it could be a sign of increasing risk as facility managers find creative ways to reduce on site inventory of COI by keeping them in transit for longer periods of time (stored at freight warehouses or train yards).

The neatest statistical anomaly is that the October Fact Sheet now reports that there are more authorized site security plans than there are covered facilities. Actually, this may be the reason that the Fact Sheet has not been publicly released yet; at the last minute someone realized that that anomaly would make the Department look a little silly.

What I suspect happened is that someone is keeping three (now four) separate spread sheets to keep track of these statistics. When a facility is removed from CFATS coverage, its name is taken off of the spread sheet of covered facilities. Apparently, however, that same facility is not being taken off of the other three lists of authorized, approved and inspected facilities.

In one way that makes sense since the Department already did the work on authorizing the facility site security plan so they should get credit for that work. On the other hand, if this is the reason for the data anomaly then we cannot really tell from the data in the Fact Sheet how many facilities have yet to have their SSP authorized.

Another potential explanation is that a facility could have completed the SSP submission process and had the SSP authorized and then had to submit a new Top Screen that required a substantial rework of the SSP which got counted as a new authorization when it reached that stage of the process. If that is the case it is an even more confusing data point.

This is one of the problems that one runs into when numbers are reported without explanation. ISCD started this voluntary data reporting out of self-defense a couple of years back. And they took the easy way out by just simply publishing numbers without explanations, probably because they really did not have a spare person to keep up with this type of reporting. ISCD has been having the same type of hiring and retention problem that we have been seeing across the entire Department. And, there personnel authorization has never really been that high considering the number of facilities covered and the detail of inspection that ISCD has been attempting to accomplish.

It will be interesting to see if this version of the October Fact Sheet ever gets officially published.

NOTE: The link to this Fact Sheet was published today on the CFATS web site. No explanation was provided for the data discrepancy. {Added 9:20 pm CDT; 10-8-15}

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