ISCD Updates CFATS Monthly Update Page – 03-13-18

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) updated their Chemical Facility Anti-Terrorism Standards (CFATS) Monthly Update page reflecting the changes in the implementation of the CFATS program that apparently took place last month (there is no effective date given for the data). The numbers continue to show progress in the implementation and compliance verification efforts of ISCD.

ISCD Activities

The table below shows the reported numbers for the key activities undertaken by ISCD in support of the implementation of the CFATS program.

CFATS Activities	Jan-18	Feb-18
Authorization Inspections to Date	3225	3352
Authorization Inspections Month	97	133
Compliances Inspections to Date	3176	3249
Compliances Inspections Month	63	79
Compliance Assistance Visits to Date	3873	4007
Compliance Assistance Visits Month	122	172

We continue to see an increase in the number of Authorization Inspections being conducted as more of the newly added facilities from the CSAT 2.0 process move through the Site Security Plan submission process. This number should level off and then decline in the coming months as more facilities move into the program compliance stage.

Facility Status

The table below shows the status of the facilities currently covered by the CFATS program. Note: there were two typographical errors on the web page table; the ‘authorized number’ was shown as ‘6665’ and the ‘total’ was shown as ‘4007’.

CFATS Facility Status	Jan-18	Feb-18
Tiered	576	474
Authorized	600	665
Approved	2339	2345
Total	3515	3485

The numbers for tiered facilities continues to go down as these newly tiered facilities move through the CFATS implementation process. The numbers for authorized facilities reflect the movement of facilities through the site security plan implementation process.

The total number of covered facilities shows an apparently increasing number of facilities leaving the CFATS program. I would assume, however, that the earlier months increases in the total numbers, reflecting the new facilities being added by the CSAT 2.0 implementation, masked a substantial number of facilities leaving the program. Facilities have substantial financial incentives to exit the program and there are a number of legitimate methods of risk reduction/elimination that facilities can employ that would allow them to exit the program.

Commentary

ISCD does not include, what is to my mind, a very important statistic in their monthly report; the results of the compliance inspections that have been conducted by the Chemical Security Inspectors. I expect that we will be seeing a new report from either the Congressional Research Office or the Government Services Agency as part of the Congressional review of the program leading to a reauthorization decision later this year. That report should cover the compliance inspection results data.