ISCD Updates CSAT 2.0 Web Site

Last week the DHS Infrastructure Security Compliance Division (ISCD) updated their Chemical Security Assessment Tool (CSAT) web page; this is part of the extensive web site for the Chemical Facility Anti-Terrorism Standards (CFATS) program. The only change to the CSAT page was the addition of a link to the new CFATS Site Security Plan (SSP) Submission Tips web page.

This new web page is part of the on-going ISCD outreach program to the CFATS regulated community. It is not a substitute for the SSP manual and the Risk Based Performance Standards (RBPS) Guidance manual, but rather a highlight of those types of things that have apparently been found lacking in many SSP submissions in the past. It highlights four major areas of concern:

• Consider what security measures to address;

• Detail current security measures;

• Describe planned security measures; and

• Specify facility-wide or asset-specific security measures

 What Security Measures

Of course, facilities are going to need to address security measures in each of the 18 RBPS that are applicable to the DHS chemicals of interest (COI) identified on the facility tiering letter. This section of the web page addresses five “overarching objectives” of the SSP:

• Detection;

• Delay;

• Response;

• Cyber; and

• Security Management

These are covered in short (one paragraph) discussions and links to the four RBPS fact sheets that ISCD began issuing earlier this year:

RBPS 8, Cyber Fact Sheet  

RBPS 9, Emergency Response Fact Sheet  

RBPS 12, Personnel Surety Program Fact Sheet  

RBPS 18, Records Fact Sheet 

Current Security Measures

This section briefly covers two rather broad topics:

• Be as detailed as possible; and

• Don’t overlook safety and environmental measures already in place that contribute to security.

In my conversations with folks in the field the first point is probably the most important for a successful SSP submission. This new web page says it well and succinctly:

“The text boxes in the Chemical Security Assessment Tool’s (CSAT) (/chemical-security-assessment-tool) SSP application have been included so that facilities can more fully describe current security measures, including how the measures address the relevant RBPS. The better DHS can conceptualize and understand your approach to security measures, the better DHS can evaluate whether they meet the applicable RBPSs.”

Facility-Wide vs Asset-Specific

The discussion here is important, though more than a little simplified (to be expected in a short document like this). It boils down to this. Security measures can be quite expensive, especially as the size of a facility increases. Since different types of COI may require different types of security measures, a facility may be able to significantly reduce costs by confining certain security measures to just those areas where their listed COI are stored or handled. Provisions are made in the CFATS to allow facilities to do this.

Commentary

Again, ISCD has consistently tried to reach out to the CFATS community and provide the necessary information to successfully comply with the program requirements. This is part of that outreach. It is not (nor was it intended to be) the ultimate word in developing a successful SSP submission. It is just part of the process.

Facility security personnel will find this helpful only if they are familiar with the RBPS Guidance document and the SSP manual. Another source of useful information in this matter are two of the recently published presentations from the 2017 Chemical Sector Security Summit:

CFATS Regulatory Update

CFATS Compliance Lessons Learned

In fact, the CSSS web site has links to additional presentations from previous years that will also be helpful. The whole CSSS program is helpful for anyone interested in chemical facility security issues.

One final point, cybersecurity continues to pop up regularly in any discussions about the CFATS program. ISCD is certainly taking great pains to mention the topic whenever they discuss site security plans or compliance inspections. They have taken particular care to ensure that they try to communicate that ‘cybersecurity’ is not only important for the control systems that touch on the handling and/or storage of covered COI, but also includes cybersecurity measures to protect security controls (surveillance, intrusion detection, and access control systems) as well as business systems that affect the handling (ordering, selling or transporting), or storage of covered COI.