ISCD Publishes CFATS Update – December 2017

Today the DHS Infrastructure Security Compliance Division (ISCD) updated the data on the Chemical Facility Anti-Terrorism Standards (CFATS) Monthly Update page. The new data for December 2017 shows the continued progress being  made implementing the CFATS program.

Facility Status

The table below shows the change in the current covered facility status for those facilities covered by the CFATS chemical security program over the last two months. A decline in the number of ‘Tiered Facilities’ is expected as recently tiered facilities complete their site security plans and have those plans authorized and ultimately approved.

CFATS Facility Status	Nov-17	Dec-17
Tiered	843	723
Authorized	429	493
Approved	2276	2340
Total	3548	3556

It looks like ISCD has completed the notification process for facilities to resubmit Top Screens in support of the implementation of CSAT 2.0. The increase in the number of covered facilities appears to be leveling off. Based upon program history, I would not be surprised to see the number of covered facilities start to actually decline.

ISCD Activities

The next table shows the activities that ISCD had taken during the month of December to support the CFATS program. The ‘to Date’ data reflects the total number of inspections/visits that have been completed since the CFATS program began.

CFATS Activities	Nov-17	Dec-17
Authorization Inspections to Date	3102	3132
Authorization Inspections Month	70	49
Compliances Inspections to Date	3065	3112
Compliances Inspections Month	87	77
Compliance Assistance Visits to Date	3723	3799
Compliance Assistance Visits Month	92	100

ISCD continues to have problems with reconciling the reported number of monthly inspections/visits and the number of those visits to date. Looking at the ‘Authorization Inspection’ data we see an increase of just 30 inspections done since the last report while reporting that there were 49 inspections completed in December. We see a similar difference in the compliance inspection and compliance assistance visit data.

In the past the discrepancy has been the other way; with a larger increase in the cumulative inspections than was reported as having been conducted. I had suggested in earlier blogs that these earlier data oddities could be explained by a number of facilities leaving the program or failing inspections. Neither of those explanations would explain the differences seen this month.