ISCD Publishes CFATS Update – 08-07-18

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) updated their Chemical Facility Anti-Terrorism Standards (CFATS) Monthly Statistics page to reflect the current status of the implementation of the CFATS program. The reported numbers show small changes in facility status and a decline in ISCD activity.

ISCD Activity

The table below shows the reported numbers for ISCD activities for the month of July. It shows a decline in all activities during the month of July with a sharp decline in the number of compliance inspections conducted. The decline in numbers may be due to vacations; Chemical Security Inspectors do deserve time off too.

CFATS Activities	May-18	Jun-18	Jul-18
Authorization Inspections to Date	3652	3713	3768
Authorization Inspections Month	59	66	44
Compliance Inspections to Date	3553	3684	3752
Compliance Inspections Month	140	131	59
Compliance Assistance Visits to Date	4359	4463	4598
Compliance Assistance Visits Month	109	113	103

The numbers reported continue to show statistical anomalies. I continue to expect that the number of activities reported for the month should match with the change in that activity ‘to Date’. The numbers do not match and there is no consistency (month-to-month or category-to-category) in the variation. The only consistency is that the number of reported monthly activities is typically smaller (never larger) than the change in the ‘to Date’ numbers reported.

I have given up trying to explain potential reasons for this discrepancy, but it does make any statistical analysis of the reported numbers suspect.

Facility Status

The next table shows the reported numbers for CFATS facility status. The changes from last month are in the expected directions but the magnitude of the changes are much smaller than expected, even given the lower activity levels reported for the month.

CFATS Facility Status	May-18	Jun-18	Jul-18
Tiered	293	216	213
Authorized	628	623	618
Approved	2468	2528	2531
Total	3389	3367	3362

The number of ‘Tiered’ facilities should generally decline as newly tiered facilities start to get their site security plans authorized. We could see periodic upticks when ISCD identifies a new class of facilities that should have (but has not yet) submitted Top Screens, but this should be relatively infrequent at this point in the program.

Similarly, the count of ‘Authorized’ facilities should generally decline as facilities transition through the category from 'Tiered' to ‘Approved’. The ‘Approved’ category is more difficult to predict at this point in the program. I would expect that generally the number of facilities transitioning from ‘Authorized’ to ‘Approved’ should be greater than the number of facilities that are leaving the program. That will change as the program continues to mature and the number of ‘new’ covered facilities continues to decline.

The problem this month is that the changes in status, while in the expected direction, are so small in magnitude. For example, there is only a small increase (3) in the number of ‘Approved’ facilities while there were 44 (reported) authorization inspections conducted. I do not expect that those two numbers should be the same; there is after all a lag to be expected between the conduct of the inspection and the actual approval of the site security plan as ISCD headquarters reviews the inspection results. The numbers should, however, be close since there should be some carryover approval from the inspections completed during the previous month. And, we cannot explain the discrepancy by assuming that an inordinate number of previously approved facilities were dropped from the program; we only had a small decline (5) in the number of covered facilities.

Again, I have no explanation for the discrepancies. I do not think that ISCD is cooking the books; that should lead to discrepancies of exaggeration not minimization. I do think, however, that these anomalies should be looked at and explained. Hopefully, the expected GAO report on the program will do so.

Regional Meeting News

With the completion of the third (and final) regional meeting last week, ISCD announced on its CFATS landing page that they will be publishing copies of some of the presentation slides on the Chemical Sector Regional Events web page. I’m looking forward to that.