ISCD Publishes December CFATS Update

Today the DHS Infrastructure Security Compliance Division (ISCD) published the December CFATS Update. The Chemical Facility Anti-Terrorism Standards continues to show modest increases in the number of authorized and approved site security plans (SSPs) and larger numbers of compliance inspections. And the number of covered facilities continues to decline.

	November 2015	December 2015
Covered Facilities	3,146	3,110
Authorized SSPs	3,242	3,258
Approved SSPs	2,256	2,271
Compliance Inspections	295	378

There has been a sharp decline in the rate of increase in the number of authorized and approved SSPs. Since ISCD is continuing to report the total number of SSPs authorized instead of the current number of facilities with authorized SSPs it is hard to tell if the decline in the rates of authorizations and approvals is due to a dwindling pool of facilities with submitted but not yet acted upon SSPs or if it is due to resources being switched to conducting compliance inspections. Complicating the assessment of the reason for the lowered rates is the knowledge that there are at least 21 open Chemical Security Inspector positions.

Again the Department continues to report declining numbers of covered facilities without offering an explanation of why the facilities have been able to leave the program. Since these reports from ISCD do not include a tally of the new facilities that are added to the program (probably not a high number on a monthly basis) there is not even a way to make a reasonable attempt to determine how many facilities have actually left the program beyond the ‘More than 3,000’ that is listed every month.