ISCD Publishes CFATS Update – August 2018

Today the DHS Infrastructure Security Compliance Division published their latest monthly report on the implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) and how that implementation has been affected by the introduction of the CSAT 2.0 assessment process. That report shows continued progress in the authorization, approval and compliance inspections of site security plans (SSPs) at CFATS covered facilities while the number of covered facilities continues to increase.

Table 1 below shows the information that was reported for the facilities that are currently in the CFATS program with a comparison to the same data reported in July.

Current Facilities	July 2017	August 2017	∆
Covered Facilities	3,018	3,381	+237
Authorization Inspections	2,347	2,346	-1
Approved Security Plans	2,266	2,271	+5
Compliance Inspections	2,025	2,070	+45

Table 1: Current Facility Data

The sharp increase in the number of covered facilities is related to letters that ISCD sent out to facilities that had previously submitted Top Screens, but were determined under the old risk assessment process to have not met the risk assessment requirements needed to be required to participate in the CFATS program. ISCD has been sending the notification letters out on a periodic basis since last October. Since facilities have 90 days from when they receive the letter to respond with a Top Screen Submission, and there is probably some minor variation in the time necessary to review and determine the risk status of the submitting facility, there is an expectation that there should be some variation in the number of facilities added to the covered facility list each month.

The drop in the number of current facilities with completed authorization inspections is indicative of the fact that a it is expected that a certain percentage of the currently covered facilities, after they submit the CSAT 2.0 Top Screen will be determined to no longer meet the risk criteria for remaining in the CFATS program. From the numbers provided in this report it is difficult to tell how many facilities left the program this month, but obviously some did.

Table 2 shows the data reported by ISCD for ‘Since the inception of the Program’; that is the total number of inspections and security plan approvals completed by ISCD since the program began in 2007.

Total Facilities	July 2017	August 2017	∆
Authorization Inspections	2,923	2,932	+9
Approved Security Plans	2,732	2,750	+18
Compliance Inspections	2,323	2,544	+221

Table 2: Total Facilities Report

The new facilities that have joined the CFATS program since the CSAT 2.0 implementation have a way to go yet before they start getting their first authorization inspections. Most of them are just starting to develop their site security plans. This means that the information reported in Table 2, at this point, all refers to facilities that have been in the program before CSAT 2.0. It is good to see the large jump in the number of compliance inspections that have been completed, even though the report continues to not provide any data on the passage rate of those inspections.

As we start to think ahead to the reauthorization of the CFATS program that is probably going to take place in the next year, we can expect to see at least a few trips to the Hill for the management team at ISCD. They are going to expect to face some questions about the data being reported here. ISCD did do fairly comprehensive report on the 8,000 (of an expected 27,000) new Top Screens that were submitted, but that data will have to be updated for Congress as well. And I expect that the Government Accountability Office personnel are already asking questions so that they can prepare their inevitable report to Congress.