ISCD Publishes CFATS November Update – 12-7-20

Today the CISA Infrastructure Security Compliance Division (ISCD) updated their Chemical Facility Anti-Terrorism Standards (CFATS) Monthly Statistics page to provide information for Chemical Security Inspector activities and facility status for the month of November.

CSI Activities

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

Inspection Data	Aug-20	Sep-20	Oct-20	Nov-20
Authorization Inspections	24	31	21	14
Compliance Inspections	107	131	90	68
Compliance Assistance	115	140	100	102
Compliance Audit	9	23	5	0

The web page does not explain the month-to-month variations in the CSI activities. The numbers this month continue the decline in activities that we saw last month. The November numbers dropped to the lowest levels since the Federal Funding Fiasco in December 2018. Since the largest component of that drop is the number of Compliance Inspections conducted, it is possible that this is due to a drop in the number of facilities that are due for their periodic re-inspections; it is just not yet time for the CSI to come back and check facility site security plan compliance again.

Facility Status

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

Facility Status	Aug-20	Sep-20	Oct-20	Nov-20
Tiered	124	108	90	85
Authorized	147	159	161	146
Approved	3056	3053	3048	3050
Total	3327	3320	3299	3281

We are continuing to see a rather sharp drop in the number of facilities covered under the CFATS program. This has been a general trend since the program began. There is, of course, a financial incentive for companies to try to reduce their level of risk of a terrorist attack by reducing or eliminating the inventory of DHS chemicals of interest at the facility. Unfortunately, with the ongoing COVID-19 pandemic, it is also possible that the sharp decrease seen in covered facilities over the last two months may be partially attributable to facility closures or declining manufacturing rates.