ISCD Updates Monthly Statistics – 9-1-20

Yesterday the CISA Infrastructure Security Compliance Division (ISCD) updated their Monthly Statistics page showing the ongoing operations and facility status in the Chemical Facility Anti-Terrorism Standards (CFATS) program. ISCD’s chemical inspectors continue to show a relatively aggressive operating tempo in a COVID-19 environment. Facility status information shows an apparent increase in the rate of facilities leaving the program.

ISCD Activities

The table below shows the activities conducted by the CFATS chemical security inspectors during the month of August.

Inspection Data	May-20	Jun-20	Jul-20	Aug-20
Authorization Inspections	0	1	10	24
Compliance Inspections	4	35	76	107
Compliance Assistance	0	198	162	115
Compliance Audit		27*	8	9
Total	4	261	256	255

The 27 Compliance Audits listed for June

were not included in the June report.

See here for last month’s report and an explanation for the new ‘Compliance Audit’ terminology.

The COVID-19 activity rate is higher than the average activity rate (214.5 activities reported per month) for CSI in the first seven months of 2019 (the last months where I kept detailed analytical records).

Facility Status

The table below shows the status of the facilities currently in the CFATS program.

Facility Status	May-20	Jun-20	Jul-20	Aug-20
Tiered	158	150	139	124
Authorized	138	130	141	147
Approved	3039	3061	3057	3056
Total	3335	3341	3337	3327

It is always a challenge trying to determine from this data exactly how many facilities have actually left the CFATS program. New facilities may have been added to the program as Top Screen submissions continue and there is status movement from Tiered to Authorized and Authorized to Approved to further complicate matters. I would confidently say ten facilities left the program, but it could have been more depending if new facilities were added to the program in the last month.

Facilities can leave the program if their status as being at ‘high risk of terrorist attack’ changes due to modifications in their inventory of DHS chemicals of interest causes a drop below appropriate thresholds.