ISCD Updates Monthly Statistics – 11-16-20

Today the CISA Infrastructure Security Compliance Division (ISCD) published their monthly update of statistics for the Chemical Facility Anti-Terrorism Standards (CFATS) for Chemical Security Inspector activities and facility status for the month of October.

CSI Activities

The table below shows the activities conducted by the CSI in October.

Inspection Data	Jul-20	Aug-20	Sep-20	Oct-20
Authorization Inspections	10	24	31	21
Compliance Inspections	76	107	131	90
Compliance Assistance	162	115	140	100
Compliance Audit	8	9	23	5

The web page does not explain the month-to-month variations in the CSI activities. While the numbers this month show a sharp drop off from the previous three months, they are slightly above the average (214.5 activities per month) number of activities that were typically undertaken in 2018 and 2019 (last data that I tabulated).

Facility Status

The table below shows the status of facilities covered under the CFATS program.

Facility Status	Jul-20	Aug-20	Sep-20	Oct-20
Tiered	139	124	108	90
Authorized	141	147	159	161
Approved	3057	3056	3053	3048
Total	3337	3327	3320	3299

This is the largest one-month drop in the number of covered facilities since 26 facilities were dropped in January 2019. ISCD does not explain why facilities are removed from the program. One ‘common’ reason for such removal would be facilities making changes in the inventory of DHS chemicals of interest (COI) that bring them below the threshold for being considered a high-risk facility. Facilities that are able to do this can avoid the regulatory costs of compliance with the Site Security Plan requirements of the program. Of course, going-out-of-business is another reason for facilities to reduce their COI inventories.