Monday, March 26, 2018

ISCD Publishes CFATS Quarterly – March 2018

Today the DHS Infrastructure Security Compliance Division (ISCD) published a news item on their Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center that the latest issue of the CFATS Quarterly Newsletter had been released. Additionally, ISCD published a new fact sheet in their chemical protection for specific industry sector series; this one is for the pulp and paper industry.

CFATS Quarterly

This issue of the Quarterly continues the tradition of a user-focused (as opposed to agency-focused) newsletter intended to provide useable information to the regulated industry. The first and last articles address specific Risk Based Performance Standard (RBPS) issues, and both lead with interesting questions.

The first deals with the ‘know your customer’ requirements under RBPS 5. It addresses the idea of preventing a business from inadvertently shipping DHS chemical of interest (COI) to potential terrorists and, thus, obviating their need to stage a physical attack on the covered facility. There is a nice segue to the introduction of the flyer ISCD published last year reminding customers that receive COI of their potential CFATS reporting requirements. One important item missing from the RBPS 5 discussion is guidelines on reporting attempts of acquiring COI by questionable entities.

The last article of the newsletter looks at RBPS 9 and the need for building relationships with local emergency response personnel. It includes a list of possible activities that a facility might want to consider, including a fairly innovative one; “Creating a toolkit for responders that contains items like the facility emergency contacts, facility layout, access credentials or a two-way radio”. I particularly like the idea about the radio, but I doubt most facilities want to spring for providing enough radios for all of the potential response agencies. An alternative would be to have this type of tool-kit available at the front gate for responding units.

In between these two articles are additional bits of useful information and one small agency ‘look-at-me’ piece. Without pointing fingers, this is the type of publication that agencies should publish, not 3-color glossy corporate-reports.

Pulp and Paper Industry

Last year, as part of their industry outreach program, ISCD started publishing a series of CFATS fact sheets that looked at various industry groups and the chemicals used by companies in those industries that could make them subject to the CFATS program. Since the CFATS program is a chemical security, as opposed to chemical industry security, program it appears to be necessary to remind various companies of their legal reporting responsibilities under the CFATS program.

The latest version is for the Pulp and Paper industry. Most of the content of these different outreach flyers are the same, as they deal with the CFATS program requirements. The only ‘new’ information here is the listing of common chemicals in the pulp and paper industry that are listed COI and thus could trigger CFATS reporting requirements.

I do wish that ISCD had provided a link to their ‘First Steps’ factsheet in this (and all of the other industry factsheets). It provides a brief overview of how to proceed when a facility has determined that they have a CFATS reporting requirement. It would be a valuable addition to these industry factsheets.

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