Tuesday, May 9, 2017

ISCD Resumes Publishing Monthly Updates

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) resumed the publication of their monthly updates on the implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) program. The previous series of updates stopped in October of last year when ISCD started the implementation of the new Chemical Security Assessment Tool (CSAT) 2.0.

New Format

As expected with the change in both the CSAT tools and the new risk assessment methodology, ISCD has changed both the formatting and information provided in the new Monthly Update. The table below shows the data being presented:

Total Facilities
Current Facilities
Covered Facilities

Authorization Inspections
Approved Security Plans
Compliance Inspections
Table 1: Reported Data


A couple of notes here. First I changed the wording of the headings for the two data columns, the information is the same, but I think my wording is clearer. The Updates does note that some previously tiered facilities have been dropped from the CFATS program since they had their site security plan (SSP) authorized, approved, and/or inspected for a variety of reasons. An overview of the possible reasons is provided, but no details about the numbers for each category.

I added the ‘Covered Facilities’ line to the table above; it is not in the Update table. The number for the current facilities is provided in the text of the update. What would have been interesting to see here is listing of the total number of facilities that had, at one time or another, been a covered facility. The last number we had before CSAT 2.0 was 2,948, but the first Fact Sheet (April 2013) showed 4,382 facilities and the number has certainly been higher than that.

ISCD does report in the body of the new Update that they will probably see a continuing increase in the number of covered facilities, at least in the near term. This is due to their continuing to send out Top Screen notification letters to facilities that are currently not covered, as I explained late last month.

Given the 2015 GAO report on the CFATS program and its reporting of problems with compliance inspections it still disappoints me to see ISCD publish numbers of compliance inspections conducted without reporting on the pass/fail numbers on those inspections. I really do expect that ISCD can now report much better than the nearly 50% failure rate that GAO reported in 2015.

I am glad to see that ISCD has resumed publishing this update. The congressional pressure that was the impetus for providing this data back in 2013 is no longer present. That makes this that much more impressive that ISCD is sharing this information.

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