ISCD Changes Monthly Status Reporting

Today (okay, yesterday now on the East Coast) the DHS Infrastructure Security Compliance Division (ISCD) changed the way they are reporting progress on the implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) program. They scrapped the monthly .PDF CFATS Fact Sheet format and added a new web-page to the CFATS web-site that provides a slightly different look at the progress being made.

Inspection Reporting

Long-time readers of this blog will no doubt recall the monthly parsing of data that I have been doing since the CSAT 2.0 reporting began back in May of this year. With ISCD reporting inspection data both on inspections ‘since the inception of the program’ and on ‘at currently covered facilities’ I had fun trying to figure out how many inspections had actually been completed that month and how many facilities were undergoing multiple inspections due to failure to achieve compliance.

The new web page changes that reporting. It still carries on with reporting the number ‘since the inception of the program’, but it now simply reports a single number for the number of inspections (Authorization, Compliance, and Compliance Assistance) conducted during the month. The table from the November 2017 reporting is shown below.

Activity	Since Inception	November 2017
Authorization Inspections (AIs)	3,102	70
Compliance Inspections (CIs)	3,065	87
Compliance Assistance Visits (CAVs)	3,723	92

If we try to compare the ‘since inception’ numbers from this newest report and those from the old style November report (ISCD used to name their reports for date of reporting not the month the inspections were done). It would appear that there were 87 AIs completed and 111 CIs done in November. This discrepancy may be due to reporting format changes or a couple of other possible program issues. It is hard to tell from a single data point.

Facility Status Reporting

A new set of data being reported on the web page is CFATS Facility Statuses. Kind of an ugly title but, it is an interesting new set of information. Previously, ISCD only published monthly numbers on the number of facilities covered under the CFATS program and the number of currently approved site security plans (SSPs). The new web page provides a table showing a snapshot of the current status of facilities in the program.

Status	Currently Covered
Tiered	843
Authorized	429
Approved	2,276
Total	3,548

This new table provides us with data on the number of facilities that have received Tiering Letters (Tiered) but have not yet had their site security plan authorized. It also tells us how many are pending approval of their SSPs, how many have approved SSPs and the sum of the above tells us how many facilities are currently covered by the CFATS program.

Interestingly, since the resumption of program status in May, there has been a net gain of 978 facilities in the program. Most of these, presumably, were added due to the revised risk assessment process and CSAT 2.0 resubmission of Top Screens, though ISCD has continued to vigorously reach out to the chemical community to identify facilities that should have been submitting Top Screens, but, for one reason or another, have failed to do so. This is a fall smaller number than the 1272 facilities that have not yet had their SSPs approved. It is highly unlikely that a significant number of the new facilities have had their SSPs approved since May. Thus, it looks like we may have had about 300 facilities fall-out of the CFATS program since reporting resumed in May. That would not be out of line with what ISCD reported as being the drop-out rate for the new risk assessment process.

Missing Data

I continue to have problems with the ISCD compliance inspection data. The data being reported today for ‘compliance inspections since inception’ and the numbers reported in the last monthly report show that there should have been 111 compliance inspections completed in November, not the 87 being reported here. Again, there could be a number of different explanations, but I continue to suspect that the 87 inspections being reported in November only reflects one-inspection (the latest) per facility.

In the past couple of months, I have been focusing on the potential for these re-inspections being required because of facilities failing their compliance inspection and thus requiring a re-inspection. ISCD broadly points out another category of facilities being re-inspected:

“It is also important to note that this regulatory program is cyclical in nature, meaning activities such as Compliance Inspections are recurring. ISCD began conducting recurring Compliance Inspections in March 2017.”

It would be helpful if ISCD were a little more specific what the 87 number being reported actually means. Was that the total number of compliance inspections done in November or the increase in the number of facilities with a current compliance inspection. And just to make things perfectly clear, it would be helpful to have a number of compliance inspections passed/failed as well.

Actually though, I really am impressed with the effort that ISCD takes to keep the chemical security community up-to-date on the progress that is being made in the program. And the progress really is an important reflection on the daily efforts by the 150 or so Chemical Security Inspectors working with the employees and contractors at the 3,548 CFATS sites on an on-going basis to reduce the risk of a terrorist attack on these facilities. Everyone involved is to be commended on the time and effort being put into this program.