Wednesday, October 31, 2018

ISCD Updates CFATS Web Site – 10-30-18

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) updated their Chemical Facility Anti-Terrorism Standards (CFATS) program web site. Significant changes were made to the CFATS landing page and the CFATS Resources page. Actually, the changes to the landing page were mainly the removal of the ‘CFATS Announcement’ section that dated back to August.

CFATS Resources

The CFATS Resources page is basically a listing of links to publications about the CFATS program. A new category of documents (Industry-related Chemicals Fact Sheets) was added to the page and a new fact sheet (CFATS Resubmitting a Top-Screen Fact Sheet) was added to the existing Fact Sheets section of the page.

The new industry fact sheets section provides links to a number of industry specific fact sheets about the CFATS program. These fact sheets are part of the ongoing outreach effort that CFATS is undertaking to ensure that all facilities with holdings of DHS chemicals of interest (COI) know about their CFATS Top Screen reporting requirements. I have written about a number of these fact sheets as they have been published, but this new section provides links to fact sheets that I had not seen before. Nothing really new in the fact sheets, they are just targeting industries that had not yet been singled out for attention. The new industries include:

There is one minor problem with this new ‘fact sheet’ section on the page; all of the links take you to the same separate ‘Industry-related Chemicals Fact Sheets’ page where an identical list of industries provides links to the actual fact sheets. It would be less disruptive if that intermediate page were removed.

NOTE: These new fact sheets were also reported on the CFATS Knowledge Center.

Resubmitting a Top Screen

This new fact sheet (actually dated ‘November 2018’) addresses the issue of when facilities are required to resubmit Top Screens. In addition to the Tier-specific periodic resubmission specified in the CFATS regulations it mentions the ‘material modification’ requirements. ISCD has had a continuing problem with providing industry with a concrete definition of this slippery term. The major reason for this is that ISCD has not been willing to share the details of their risk assessment model so that industry could see exactly what type and scope of changes could result in a change of their facility tiering.

This new fact sheet does provide some new information. Along with the addition or deletion of a COI from the facility inventory, ISCD now lists “Changes to quantity, location, or packaging of a COI as previously reported on a Top-Screen” as a category of activities that could trigger a requirement to resubmit a Top Screen.

To limit the number of Top Screen submissions that a facility might have to submit, ISCD does offer this bit of advice:

“As a best practice, DHS recommends that a facility predict the highest expected quantity and concentration of COI it anticipates possessing at a given time over the lifecycle of the facility’s operations to ensure more efficient reporting.”

Unfortunately, following this advice will could also result in the requirement to maintain a security system for a Tier ranking higher than the facility deserves on a routine basis. It would be more helpful to facilities if ISCD were able to tell facilities what level of inventory for currently listed COI would trigger an increase in Tier ranking. That way facilities could put administrative controls into place to ensure that that inventory level was not reached without a specific consideration of the costs of added security measures.

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