ISCD Publishes March 2016 CFATS Update

This morning the folks at the DHS Infrastructure Security Compliance Division (ISCD) published their latest update information about compliance activities surrounding the implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) site security plan program. The numbers show continued improvement in the number of facilities that have approved site security plans (SSPs) and a continued increase in the number of compliance inspections the Chemical Security Inspectors (CSI) have done.

	January 2016	February 2016	March 2016
Covered Facilities	3,088	3,083	3,074
Authorized SSPs	3,285	3,305	3,324
Approved SSPs	2,354	2,391	2,449
Compliance Inspections	450	532	624

ISCD is continuing to report more facilities with authorized SSPs than there are currently facilities in the program. ISCD has yet to explain whether they are continuing to report authorized SSPs for facilities that are no longer in the program or if they are just reporting multiple versions of the SSPs for the facilities that remain in the program. In either case, it makes it impossible to tell how many more SSPs that ISCD has to authorize or approve.

The March numbers (actually for activities in February) show an increased rate in approvals and compliance inspections. If the rate for this last month continues, ISCD should complete the SSP approval process early next year; unless, of course, they are having the same number with counting approved SSPs that they are with authorized SSPs.

The pickup in the rate of compliance inspections is important, especially since the same folks that are doing the authorization visits and approval inspections are doing the compliance inspections. As we see fewer of the non-compliance inspections being done in the future, we should see a further increase in the rate of compliance inspections.

As the number of compliance inspections increases it is going to become more important for ISCD to correct the lack of reporting on actual compliance results. More important than just the numbers of facilities here is some indication at how well the industry is doing in complying with their negotiated SSP performance standards. Last year the GAO reported a poor pass rate on the early compliance inspections and a lack of enforcement action. It would certainly be interesting to see if that has changed.

BTW: The link on the Chemical Security landing page for this CFATS update takes you to a link for last month’s update, not the March update. I have reported the direct link to the March 2016 update.