Tuesday, January 30, 2018

ISCD Publishes Updated and New Fact Sheets

Today the DHS Infrastructure Security Compliance Division (ISCD) updated the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center. The ‘Documentation’ section of the page now includes links to four new CFATS fact sheets for industries that are not normally considered chemical industries. They have also updated their two inspection fact sheets.

Industry Fact Sheets

The four new industry fact sheets are for:

Breweries; and

Sharp eyed readers will note that three of these are included in the list of fact sheets that I mentioned in my earlier blog post about the CFATS Outreach Implementation Plan FY 2018. The last three fact sheets were reportedly released in 2017, but that I had not seen them published on the CFATS web site. The pools and water parks sheet was not mentioned in the earlier document. The lab factsheet that I had also mentioned earlier as not having been seen was not included in today’s link publication.

Much of the information provided in the four fact sheets is identical. Not surprisingly, the lists of ‘typical’ DHS chemicals of interest (COI) used by the facilities is slightly different in each case. Three of the factsheets (not the one for breweries) listed included brief comments about the agricultural exemption; mainly for fertilizers applied to land associated with the facility. The fisheries factsheet however, notes that fisheries and hatcheries are not included in that exception.

Inspection Fact Sheet Updates

The two new inspection updates deal with preparing for:

These are both complete re-writes of fact sheets written in 2014 and 2016 respectively. As with the previous versions, neither of these documents real information valuable for passing of the respective inspections, but they both provide valuable information that will be helpful in preparing for the conduct of the inspections.

One interesting piece of information is included in the compliance inspection fact sheet and it relates to the scheduling of those inspections. It notes that:

“ISCD compares eight factors (seven static and one dynamic) in an automated calculation to schedule CIs. Facilities with a higher score are prioritized. Static factors included in this calculation are a facility’s tier, number of planned measures [emphasis added], the time since the last inspection, and compliance history. The eighth factor changes based on new and emerging requirements.”

The issue of planned measures has been an issue since compliance inspections were started in the CFATS program. ISCD gave facilities credit for security measures that could not be implemented immediately for some reason; usually dealing with capital expenditure, long lead time equipment and the such. As long as the facility had budgeting in place and a firm schedule for completion documented, credit was given for those measures in the approval of the facility’s site security plan. During a large number of the initial compliance inspections chemical security inspectors found that facilities were not complying with their planned implementation schedules. While mitigation measures had to be in place for these planned measures to be approved by ISCD, facilities would not be fully secured until those planned measures were completed. ISCD is obviously taking these planned security measures very seriously.

To my disappointment the Expedited Approval Program appears to have been short changed in its mention in these two documents. It is briefly mentioned in a footnote in the authorization inspection document (mentioning that an authorization inspection is not required), but it is completely missed in the compliance inspection fact sheet. The consequences for a failed compliance inspection for EAP facilities is completely different from those for a facility that has gone through the standard site security plan approval process and should have been mentioned in the compliance inspection fact sheet.

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