ISCD Updates Monthly Statistics – September 2020

Sometime last week (CISA does not date page updates any longer so I cannot pin point it more accurately than that) CISA’s Infrastructure Security Compliance Division (ISCD) updated the information on their CFATS Monthly Statistics. This page provides information on activities conducted by the Chemical Security Inspectors and statistics on facilities covered under the Chemical Facility Anti-Terrorism Standards (CFATS) program.

CSI Activities

The table below shows the activities conducted by the CFATS Chemical Security Inspectors for the last four months. Since resuming CSI activities in June, ISCD has maintained a higher operational rate for its inspectors than it saw before the COVID-19 pandemic.

Inspection Data	Jun-20	Jul-20	Aug-20	Sep-20
Authorization Inspections	1	10	24	31
Compliance Inspections	35	76	107	131
Compliance Assistance	198	162	115	140
Compliance Audit	27	8	9	23
Total Activities	234	275	255	325

Compliance Audits were a reduced-contact activity developed by ISCD in response to the COVID-19 pandemic. It was first reported in June 2020.

Facility Status

The table below shows the status of current facilities covered under the CFATS program. We continue to see a long-term trend in the gradual loss of facilities in the program. Some of this is due to changes in inventory of DHS chemicals of interest (COI), but some of the loss may be due to the closure of chemical facilities.

Facility Status	Jun-20	Jul-20	Aug-20	Sep-20
Tiered	150	139	124	108
Authorized	130	141	147	159
Approved	3061	3057	3056	3053
Total	3341	3337	3327	3320

The number of new facilities coming into the program (as reflected by the ‘Tiered’ data) is at the lowest level we have seen since the introduction of CSAT 2.0 in 2016. Some of this probably reflects the reduced number of industry events where the ISCD CFATS outreach program is able to present information about the CFATS program. More likely, however, is that the outreach program has reached a level of information saturation where there are a rapidly decreasing number of potentially covered facilities that are not aware of their reporting responsibilities under the CFATS program.

At some point ISCD is going to have to aggressively start looking for individual facilities that have willfully ignored their legal responsibility to report the presence of COI inventories. Such investigations could start with obtaining data on where COI are shipped to, or received from, by currently covered facilities. ISCD may need additional Congressional authorization to require that facilities provide this information to ISCD.