Monday, October 3, 2016

CSAT 2.0 Update – 10-03-16

On Friday the DHS Infrastructure Security Compliance Division (ISCD) updated a number of their Chemical Facility Anti-Terrorism Standards (CFATS) program reflecting the implementation of the new Chemical Security Assessment Tool (CSAT) 2.0. The big news is that as of Saturday, October 1st, ISCD is re-instating the Top Screen submission requirements for facilities that have new inventories (in the last 60 days) of DHS chemicals of interest (COI) [NOTE: this re-instatement date was actually included in the initial CSAT 2.0 Federal Register announcement.]

CFATS Landing Page

The CFATS landing page included a brief note about the re-instatement of the To Screen submission requirement. They noted that:

On October 1, 2016, the requirement to submit Top-Screens will be reinstated. Chemical facilities of interest that have not previously submitted a Top-Screen, but which have come into possession of reportable amounts of COI, must submit a Top-Screen within 60 days. Additionally, in the coming months, DHS will be reaching out directly to CFATS chemical facilities that have previously submitted Top-Screens to DHS and require that they submit a new Top-Screen using CSAT 2.0. However, facilities may choose to proactively resubmit a Top-Screen once the new tool is available and prior to receiving the individual notification.”

This same verbiage was included on a number of other CFATS related pages.

Interestingly, the list of ‘Key Documents’ on the bottom of the pages does not include the three new manuals that I mentioned on Friday morning.

CFATS Knowledge Center

The CFATS Knowledge Center added two new items in the ‘Latest News’ section. The first provided a link to another new document in the ‘Documentation’ section; the CFATS Tiering Methodology Fact Sheet (more on this later). The second item is a very lengthy discussion entitled “Chemical Facility Anti-Terrorism Standards Program Reinstates Top-Screen Requirement with Release of CSAT 2.0”. It would have been nice to see this as a separate document that would remain available on the web site for a longer period of time.

CFATS Tiering Methodology

Most of the changes to the Tiering Methodology page were discussed here Friday. The new item on Saturday was a link to the fact sheet mentioned above. Actually it is the same document but a different link. Why ISCD made the decision to store this document on two different pages, I have no idea.

This fact sheet is the first time that DHS has provided any kind of information about how the risk analysis process is used to determine if an individual chemical facility presents the high-risk of terrorist attack that would require coverage by the CFATS program and how the covered facilities are placed in their Tier rankings.

There is not really anything here that anyone with a background in security risk analysis would not have already guessed was included in the risk analysis process. I would bet that most of this was included in the old risk analysis process. The details of the analysis process are still classified, but this new fact sheet does provide some low level of insight into the new process.

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