CFATS Monthly Statistics – January 2021

Yesterday CISA’s Infrastructure Security Compliance Division (ISCD) updated the Monthly Statistics page for the Chemical Facility Anti-Terrorism Standards (CFATS) program. This page provides an overview of activities conducted by the Chemical Security Inspectors in support of the program and the status of facilities within the program. There were some significant changes last month.

CSI Operations

The table below shows the activities conducted by the program inspectors last month.

Inspection Data	Oct-20	Nov-20	Dec-20	Jan-21
Authorization Inspections	21	14	8	11
Compliance Inspections	90	68	35	69
Compliance Assistance	100	102	36	205
Compliance Audit	5	0	0	5

The sharp increase in Compliance Inspections would seem to indicate that last month’s decline was holiday related and not because of COVID-19 infections in the CSI ranks. The return of Compliance Audits last month does show that DHS is still taking COVID-19 into account in its operations planning. Those Audits were begun last summer as part of ISCD’s response to the Pandemic.

Facility Status

The table below shows the status of facilities covered by the CFATS program. There were two major changes that deserve discussion.

Facility Status	Oct-20	Nov-20	Dec-20	Jan-21
Tiered	90	85	81	103
Authorized	161	146	141	152
Approved	3048	3050	3058	3037
Total	3299	3281	3280	3292

The first item of note is the addition of at least 22 new facilities to the CFATS program, the number in the ‘Tiered’ row. Facilities become ‘Tiered’ when they submit their initial Top Screen and ISCD’s analysts determine that the facility is at ‘high-risk of terrorist attack’. Those facilities then begin the process of conducting a Security Vulnerability Assessment and preparing their Site Security.

My comment about the ‘at least 22 new facilities’ was made because there was an 11 facility increase in the number of ‘Authorized’ Facilities, facilities that oved out of the ‘Tiered’ status because they passed their Authorization Inspection. So, it looks like there were more likely 33 new facilities joining the CFATS program last month. An increase of this magnitude means that the CFATS Outreach program is working. It would be interesting to know what types of facilities were most represented in this latest class of CFATS facilities, but ISCD is unlikely to publicly discuss that.

The second number of interest is the increase in the total number of facilities in the program. The rise of just 12 facilities last month when there were probably 33 new facilities added to the program means that there was a significant number of facilities dropping out of the program in January. This is reflected in the decline in the number of ‘Approved’ facilities; 21 fewer ‘Approved’ facilities than were reported for December 2020. Please note that 21 + 12 = 33.

There are two methods that a facility can ‘drop out’ of the CFATS program. Make changes to the chemical processes that remove or reduce the on-hand inventory of DHS chemicals of interest (COI), or shutter their operations and remove the inventory of COI in response. I suspect that with the raging COVID infection rate in the country, the reason for decline in January was more related to plant closures than process changes. Again, ISCD is unlikely to tell us.