Thursday, September 8, 2016

ISCD Publishes CFATS Update – 9-8-16

Today the DHS Infrastructure Security Compliance Division (ISCD) published their latest update of their progress in implementing the Chemical Facility Anti-Terrorism Standards (CFATS) program. While there is continued progress in authorizing and approving Site Security Plans (SSPs) it was at a much reduced rate this last month. The rate of compliance inspections was also reduced this month.

As is usual, ISCD take no effort to explain their numbers or the changes in rates from previous months. We can probable guess that the reduced rate of authorizations and approvals is more related to the reduced number of facilities that are at that point in their CFATS implementation process. This is also almost certainly being impacted by the current freeze in submitting Top Screens and Security Vulnerability Assessments.

Neither of those explanations would explain the less pronounced decrease in the number of compliance inspections completed in the last month. The change in the inspection rate may be small enough to be just part of the standard variation in the way inspections are being conducted. Or it could be explained by a possible increase in the vacation rate among Chemical Security Inspectors as the time for starting school approached.

Still no word from ISCD about the reasons for the continued decrease in the number of covered chemical facilities. While we would certainly hope that the decrease is due to facilities decreasing the amount of, or eliminating the presence of, DHS chemicals of interest (COI). This is the only explanation that ISCD ever mentions, but there are some number of chemical facilities that are removed from the list of covered facilities because the company has gone out of business (I personally know of at least one). The important question is how many (if any) were driven out of business because (in all or part) of the cost of compliance with the CFATS program?

ISCD also continues to fail to report data on the compliance rate from their compliance inspections. We know that less that the compliance rate was less than 50% for the initial 80 or so inspections. That coupled with the failure of ISCD to discuss the compliance rate in more recent inspections makes one wonder just how successful the CFATS program has been in increasing the security of chemical facilities.

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