Thursday, June 29, 2017

ISCD Publishes July 2017 CFATS Update

Today the DHS Infrastructure Security Compliance Division (ISCD) published the July 2017 Chemical Facility Anti-Terrorism Standards (CFATS) Monthly Update. As with the previous report, this was published before the end-of-the-month and there is no indication of when the data cut-off dates was. This makes it hard to accurately compare month-to-month results.

DHS continues to report two sets of numerical data; one for ‘currently covered facilities’ (facilities currently in the CFATS program) and a separate set for all facilities ‘since the inception’ of the program (what I call ‘Total Facilities’). The reason for the two sets of data is that it provides a better perspective on the work that the Chemical Security Inspectors (okay, CSI, sigh) since the program began in 2007.

Current Facilities

Table 1 shows a comparison of the data reported this month and last month for facilities ‘currently’ in the CFATS program.

Current Facilities
June 2017
July 2017
Covered Facilities
Authorization Inspections
Approved Security Plans
Compliance Inspections
Table 1: Changes in ‘Current Facility’ Data

The data shows a net gain in the number of covered facilities. It is important to remember that DHS is continuing to send out Top Screen notification letters to a selection of current facilities and previously reporting facilities directing them to submit a new 2.0 Top Screen. Some of the previously reporting (but not covered) facilities will become covered facilities under the new risk assessment process and some of the current facilities will be dropped from the program because of the changes made in that assessment. Additionally, some number of facilities will continue to modify their processes and chemical inventories (or go out of business) resulting in their being dropped from the program.

The changes in the (unpublished) list of covered facilities and continuing efforts by CSI and covered facility teams also results in changes in the number of Authorization Inspections, Approved Site Security Plans and Compliance Inspections. This month there were net losses in the first two items and a net gain in the third.

Total Facilities

To get a better understanding of what that really tells us about the regulated community we need to look at the month-to-month changes in the number for all facilities since the inception of the program. Table 2 shows those numbers.

Total Facilities
June 2017
July 2017
Authorization Inspections
Approved Security Plans
Compliance Inspections
Table 2: Changes in ‘Total Facility’ Data

From this data, we can see that CSI completed five authorization inspections and 122 compliance inspections in the period between the two reports. Additionally, 6 SSPs were approved by ISCD. This would seem to indicate that we lost somewhere between 7 (the difference in the ∆ numbers for authorization inspections) and 93 (the difference in the ∆ numbers for compliance inspections) covered facilities for the covered periods.

There does seem to be a possible problem with this data (or perhaps my analysis) however. Every facility that has completed a compliance inspection must have had at least one SSP approved. Most facilities that have an approved SSP have had at least one authorization inspection (the potential exception would be the very limited number of facilities that have availed themselves of the Expedited Approval Process; their SSPs were approved based upon their certification and did not require an authorization inspection). Thus, we should expect to see a much larger loss (change since last month) in the number of current authorization inspections and site security plans based upon the ∆ for compliance inspections.

New Data Reported

I mentioned last month that ISCD had not changed the numbers in ‘**’ footnote between the May and June reports. Those numbers reflected the mix of old and new Top Screens that were responsible for the current batch of covered facilities. In both of the earlier reports ISCD reported 2,268 CSAT 2.0 facilities and 302 original Top Screens. This month they reported 2,886 and 142 respectively. The two month ∆s for those numbers are 618 and 160. Trying to tease any more information out of those numbers is going to take some additional thought.

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