ISCD Publishes Monthly Update – December 2020

This week the CISA Infrastructure Security Compliance Division (ISCD) updated their CFATS Monthly Statistics web page providing information on the activities of their Chemical Security Inspectors (CSI) and the number of facilities currently covered by the Chemical Facility Anti-Terrorism Standards. With reduced activity related to some combination of the holidays and operating in the COVID-19 environment, ISCD’s inspectors and staff continued to oversee the security of high-risk chemical facilities through the month.

CSI Activities

The first table below shows the activities of the CSI in the field.

Inspection Data	Sep-20	Oct-20	Nov-20	Dec-20
Authorization Inspections	31	21	14	8
Compliance Inspections	131	90	68	35
Compliance Assistance	140	100	102	36
Compliance Audit	23	5	0	0

CSI Activities

Activities were well down from December 2019 (16, 122, and 111 respectively) but that was a pre-COVID-pandemic month and infections were skyrocketing across the nation last month. Reducing CSI activity would be just a good management technique.

Interestingly, for two months in a row now there have been zero ‘compliance audits’ conducted. As I reported last August ISCD developed this new process to help CSI continue facility oversight in a reduced contact environment. For some reason it seems that this process never caught on, with Compliance Inspections strongly outnumbering the COVID audits every month since their introduction. After the COVID pandemic finally eases sometime later (probably much later unfortunately) this year, this a study examining this as a potential tool in future pandemics would be worthwhile.

It would also be interesting to find out how the COVID infections have directly impacted the CSI force. Knowing how many inspectors have become infected and how much time has been lost because of quarantine and isolation requirements for exposed inspectors would help to explain the reduced CSI activity levels over the last nine months.

Facility Status

The table below shows the changes in facility status in the CFATS program over the last four months.

Facility Status	Sep-20	Oct-20	Nov-20	Dec-20
Tiered	108	90	85	81
Authorized	159	161	146	141
Approved	3053	3048	3050	3058
Total	3320	3299	3281	3280

Facility Status

Not much change since the November report.