Monday, October 14, 2019

ISCD Publishes CFATS Quarterly – 10-08-19

Last week the CISA Infrastructure Security Compliance Division (ISCD) published the latest version of their Chemical Security Quarterly. Along with a large number of informational links, this version includes articles on:

CISA Leadership Updates;
House Hearing on CFATS Reauthorization;
Close-up on the Personnel Surety Program (PSP);
National Cybersecurity Awareness Month;
Chemical Sector Security Summit Presentations;
Counter Unmanned Aircraft Systems (UAS) Authorities;


Along with the brief article on the Tier III and Tier IV implementation of the PSP terrorist screening process there is a list of frequently asked questions along with the ISCD response. The article provides a nice high-level (upper management) overview of the PSP while the FAQs provide a deeper (but not too deep) dive into the mechanics of the PSP. Finally, there is a section that includes links to a number of resources on the PSP.

One minor complaint, the Chemical Security Inspectors and Compliance Analysts is a little misleading. It is just an email link to A detailed email to that address will get some sort of appropriate assistance response, but not necessarily from a CSI or compliance analyst.

Counter UAS

An interesting collection of information about UAS operations in or near critical infrastructure; unfortunately, there is nothing that directly concerns counter UAS operations at CFATS regulated facilities. The reason for this is that the legal basis for counter UAS operations is very cloudy with lots of deadly lightning bolts (to extend the ‘cloudy’ metaphor) at this point, again unfortunately, that is not made clear in this article or any of the linked information sites.

CFATS Information Updates

This section provides links to new or revised CFATS resources. In this instance the ‘new resources’ includes links to a Risk-Based Performance Standard (RBPS) 10 web page and fact sheet. This RBPS concerns maintaining all records of maintenance, testing, and calibration of security equipment, as specified in 6 CFR §27.255(a)(4).

This section notes that ISCD has revised their ‘Detect and Delay’ web site and fact sheet. The changes appear to be more editorial than substantive.

I was disappointed to see this update information here and not on the CFATS Knowledge Center page when the changes occurred. The new RBPS 10 information was apparently updated earlier this month so there was no major delay there; but the Detect and Delay information was apparently updated last May. That is hardly timely information sharing. Caveat; I am predicating my ‘timing’ information on the dates provided on the two fact sheets; there are no dates on these (or most of the) ISCD web pages.

Overall Rating – Good Job

I am typically disappointed in publications like this Quarterly report. As I have noted on numerous occasions with other agencies, they are more like Corporate Annual Reports (look how great we are) rather than information sharing efforts. ISCD continues to concentrate on information sharing rather than grandstanding.

I continue to refer to this as the ‘CFATS Quarterly’, but CISA has rebranded this the ‘Chemical Security Quarterly’. Most of the information in this issue is targeted at CFATS facilities, but the UAS article shows that CISA is trying to target this at a larger audience. I applaud them on that effort, we will see how well they expand this outreach in future editions.

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