Monday, January 22, 2018

ISCD Outreach and Shutdown

Today, the first day of the Federal Funding Fiasco 2018, the folks at DHS Infrastructure Security Compliance Division {the DHS division operating the Chemical Facility Anti-Terrorism Standards (CFATS) program} published two notes in the ‘Latest News’ section of the CFATS Knowledge Center web site. The first is a brief note about the ‘funding hiatus’ and the second is a blurb about the publication of the CFATS Outreach Implementation Plan for FY18.

Funding Hiatus

While the current federal funding authorization actually stopped at midnight last Friday, today (as the start of a ‘normal’ work week) was effectively the first day of the ‘funding hiatus’; which I prefer to call the Federal Funding Fiasco 2018. The Knowledge Center page provided the following information:

“Due to the current federal funding hiatus, some DHS personnel [emphasis added] will not be able to return emails or telephone calls until the conclusion of the funding hiatus. We appreciate your patience at this time.”

There is no specific outline of which ‘DHS Personnel’ are out of contact due to the FFF. I would have guessed that that would have included Chemical Security Inspectors, but I heard complaints during the first FFF that some inspectors were expected to work regardless. I guess the best way to tell is to try to contact folks and if they do not respond they are probably part of the ‘some DHS personnel’.

This is more information than was provided on this page during the ‘first FFF’ in 2013, however. There is a banner on the CFATS landing page (and other DHS pages) nearly identical to the one in the first FFF. Similarly, the DHS Blog entry to which that banner is linked has almost identical verbiage to the 2013 post (the dates have been changed to protect the innocent).

One significant difference on the CFATS web site this time around is that there in no notice that the CSAT system is off-line on either the Registration Page or the CSAT Portal page. Presumably this means that the automated CSAT tools remain up and running.

NOTE: After writing the above, I received news that the FFF has been at least temporarily suspended until February 8th. We will have to wait to see if we have a Part Deux. 

Outreach Program

The second note is about the publication of the “CFATS Outreach Implementation Plan FY 2018”. This is apparently (I have not seen any of the earlier documents) the third update of a plan by ISCD that was required by the current CFATS authorization {6 USC 629}. It provides an interesting summary of the outreach efforts that ISCD has undertaken to reach out chemical facilities that may be covered by the CFATS program, but that have not filed a Top Screen report that would allow DHS to make an actual determination whether or not they are covered by the program.

The lengthy (8 pages) Executive Summary of the program includes a multipage table that briefly outlines the activities included in the original FY 2015 outreach plan and where those efforts stand three years later. Some interesting data points taken from that table include:

• DHS analyzed 217 chemical incidents; identified 54 potential CFATS sites; had 19 Top Screens submitted, and designated 5 new CFATS covered facilities;
• Of the 27,000 or so facilities that submitted Top Screens under CSAT 2.0 1,900 were facilities that had not submitted Top Screens previously; of those, 270 were designated covered facilities;
• In FY17, DHS identified 519 facilities as potentially non-compliant; and
• Since 2014 DHS officials have contacted 1400 Local/Tribal Emergency Planning Committees (LEPC).

Appendix A of this document provides a list of materials that ISCD has published to support this outreach mission. Most of the documents have been covered in this blog. There are four exceptions to that coverage; I have not seen and thus have not reported on the following:

• CFATS Information for Laboratories (factsheet);
• CFATS Information for Wineries (factsheet);
• CFATS Information for Breweries (factsheet); and
• CFATS Information for Fisheries and Hatcheries (factsheet).

These factsheets were not mentioned on the Knowledge Center and, contrary to the claim at the top of Appendix A, I have not been able to find them on the Critical Infrastructure: Chemical Security web site. I do not expect that there was much to miss here, but it would have been interesting to see how ISCD tired to ‘personalize’ the CFATS program for these industries.

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