Thursday, December 10, 2015

CFATS – What to Expect from an Inspection

Today the DHS Infrastructure Security Compliance Division (ISCD) published a new document for their Chemical Facility Anti-Terrorism Standards (CFATS) program entitled “What to Expect from a Chemical Facility Anti-Terrorism Standards (CFATS) Inspection”. The document provides some basic information CFATS covered facilities need to know about authorization inspections and compliance inspections.

The sixteen page manual (in relatively large type) does not go into a great deal of detail, but the information provided is certainly valuable for organizations going through one of the two inspections for the first time. Some of the larger bullet point discussions include:

• What Is an Authorization Inspection;
• What Is a Compliance Inspection;
• Before an Inspection;
• Expediting the Onsite Visit;
• Preparation for the Inspection Team;
• What Documents for a Compliance Inspection;
• Who Should Be Present Onsite or Available During the Inspection;
• During the Inspection;
• Inspection Outbrief;
• Post-Authorization Inspection;
• Post-Compliance Inspection;

I used the term ‘bullet point’ above for a very specific reason. This booklet is essentially the “What to Expect from a CFATS Inspection” presentation by Dave Schmidt at the 2015 Chemical Sector Security Summit. Still it is valuable to have this more generally available and it is listed on the DHS Critical Infrastructure: Chemical Security web page.

BTW: There have been a number of new informational offerings from ISCD over the last two months and that is a good thing. BUT, there is still no word on when the CFATS Personnel Surety Program is going to get kicked off by the Federal Register Notice describing how the PSP will work. It took almost a year and a half to get the OMB approval of the ICR, let’s hope it does not take that long to get departmental approval for the PSP notice.

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