ISCD Publishes CFATS Update – 07-05-18

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) published their latest statistics on the continued implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) program. We continue to see a slow decline in the number of covered facilities while we see a sharper rise in the number of approved Site Security Plans (SSPs).

Facility Status

Table 1 shows the facility status for CFATS covered facilities.

CFATS Facility Status	Apr-18	May-18	Jun-18
Tiered	363	293	216
Authorized	639	628	623
Approved	2397	2468	2528
Total	3399	3389	3367

Table 1 CFATS Facility Status

The ‘tiered’ facilities are those facilities that have been notified that they are covered facilities but have not yet had their SSPs authorized. The ‘authorized’ facilities have had their SSPs authorized but have not yet had them approved. The ‘approved’ facilities have had their SSPs approved and are thus subject to compliance inspections.

Generally, we should expect to see the number of tiered facilities to decrease overtime as the facilities move through the CFATS process. New facilities will enter (or even re-enter) the CFATS program, but at this point the month-to-month number of these ‘new facilities’ should be relatively low unless ISCD discovers some new class of potentially covered facilities that has not been aware of the CFATS program.

There should also be a declining trend in the number of authorized facilities, but there will be more variability in the rate of decline. There is a regulatory time-limit for the initial submission of the facility SSP, but there is a variable time-frame after that submission for the facility and ISCD to ‘negotiate’ the provisions of the SSP that will be required for the SSP to become authorized. Another factor that affects the number of facilities in this status is the number of facilities that modify their operations so that they are no longer considered to be at high-risk of a terrorist attack and are removed from the program.

We currently see a relatively high rate of increase in the number of approved facilities. This reflects the large number of facilities that were added to the program last year as a result of the CSAT 2.0 introduction. This should begin to level out in the coming months and we will eventually reach a point where the number will decline as facilities that leave the CFATS program outnumber the number of new facilities being added.

ISCD Activities

Table 2 shows the reported activities that ISCD has been undertaking to support the implementation of the CFATS program.

CFATS Activities	Apr-18	May-18	Jun-18
Authorization Inspections to Date	3600	3652	3713
Authorization Inspections Month	110	59	66
Compliance Inspections to Date	3413	3553	3684
Compliance Inspections Month	76	140	131
Compliance Assistance Visits to Date	4238	4359	4463
Compliance Assistance Visits Month	143	109	113

Table 2 – CFATS Activities

It may be easier to see what is going on if I graph the monthly numbers for the last five months. Figure 1 shows the change in reported numbers of monthly activities as well as a combined total for those activities.

Figure 1 – Rate of Monthly Activities

The time period is too short (and ISCD has not provided effective dates of the data) to do real statistical analysis of the data in Figure 1, but it would seem that in general the trend is for fewer authorization inspections and more compliance inspections (both are expected from the discussion above). The most difficult trend to sus out is the change in rate for compliance assistance visits. This is not unexpected since these are done at the specific request of facilities.

At first glance the change in the total number of activities would seem to indicate a slowing of the pace by the ISCD inspection force. This is almost certainly misleading. These numbers reflect the number of facilities specifically ‘touched’ by the Chemical Security Inspectors, not the number of inspector hours involved or even the number of CSI involved in the activities. So we have to be careful in drawing too many detailed conclusions about the data presented. In fact, the only thing that we can probably conclude from the data presented is that the ISCD inspection force is actively engaged in the field.