DHS Begins Issuing Tiering Letters Based Upon CSAT 2.0

Today the DHS Infrastructure Security Compliance Division (ISCD) updated their “Critical Infrastructure: Chemical Security” web site to add language announcing that ISCD had begun “issuing tiering determination letters to facilities that were assessed using the enhanced methodology”.

The “Tiering Methodology” web page (also updated today) noted that:

“Based on the Department’s analysis of a representative sample of tiering results, some facilities will see a change in their tiers. Some facilities that were previously not covered under CFATS will find themselves covered, and some currently-covered facilities may no longer be considered high-risk. Some of these tier changes are a result of changes to the tiering methodology, while others are the result of changes facilities have made to their businesses, such as adding new chemicals, removing chemicals of interest, or modifying storage methods.”

DHS will be holding two webinars to discuss tiering trends and to respond to questions from facilities. The webinars will be held on:

April 24^th, 2017; and

May 3^rd, 2017

There is nothing on the web site that explains what ISCD expects facilities to do; that will be included in the notification letter sent to each facility. Facilities with added DHS chemicals of interest (COI) or upgraded Tier Ranking can expect to be notified of the need to submit a new SVA/SSP. Facilities with downgraded Tier Rankings will probably be notified of the opportunity to submit new SVA/SSPs to reflect the lower security requirements associated with the lower Tier Ranking. Facilities that are being removed from CFATS coverage will be reminded that they will still be required to re-submit Top Screens if their current COI inventories increase or new COI are added to their inventories.