Thursday, June 11, 2020

ISCD Announces COVID-19 Modified Inspections

Today the CISA Infrastructure Security Compliance Division (ISCD) published a notice on their Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center announcing that they were planning on resuming modified CFATS compliance inspections this month. The notice states:

“Effective June 2020, CISA will begin piloting three options for modified compliance operations to verify that high-risk facilities are maintaining the security measures in their security plans during this pandemic operational environment while also limiting in-person interactions between Chemical Security Inspectors (CSIs) and facility personnel. CSIs will be in contact if your facility had an inspection postponed or have an upcoming inspection. If you have any questions, please contact your local CSI or email”

While ISCD announced back in March that they were stopping most site visits (including inspections) in support of COVID-19 restrictions, they never did complete stop their inspections. According to the CFATS Monthly Statistics page there were 4 compliance inspections completed last month and the earlier version of that page reported 2 compliance inspections in April. There were no details provided as to why ISCD decided to conduct these six inspections despite the COVID-19 restrictions. My guess is that the inspected facilities had failed previous inspections and CISA decided that it was important to ensure that the facilities were currently in compliance.

No details are available for the three options mentioned in today’s notice. I would expect that facilities that are expecting routinely scheduled re-inspections may be offered an option for an electronic meeting with the CSI assigned to the facility to review the current status of the facility operations and security measures. This might also include a requirement for live videos of security measures.

I would suspect that for facilities that are currently closed, I would expect that ISCD might want to send a CSI to physically visit the facility and tour the facility with a designated representative to ensure that appropriate measures have been taken to keep the facility secure while under limited operations due to the COVID-19 pandemic.

I have not idea what the third (middle?) option would be.

I will see what I can find out. Facility security managers should certainly reach out to their assigned CSI.

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