Sunday, May 2, 2021

CFATS Post-Pandemic

We are getting close to the end of the COVID-19 Pandemic and all of the changes that it has wrought on the world in general and the Chemical Facility Anti-Terrorism Standards (CFATS) program in particular. What will that brave new world look like?

The End of the Pandemic

It is unlikely that the pandemic will just stop being. We are likely to see a continuing loosening of restrictions as more people get completely vaccinated. We already see a gradual decline in the vaccination rate, and it is becoming clear that we will have a relatively large segment of the population that will not accept a free vaccination for a variety of reasons.

At this point it is not clear if that anti-vax sentiment will prevent the country from reaching ‘herd immunity’. That is the point where the rapid spread of COVID-19 would no longer be possible because the likelihood of an unprotected person coming in contact with an infected person is low enough that most cases will not result in another person becoming infected.

Scientists still do not know enough about the COVID virus to be able to give us (and more importantly the government) a firm figure about how many people have to be protected (either by vaccine or previous infection) to be able to declare the pandemic over. And making the problem even more difficult the ongoing mutation of the virus is going to continue to produce new strains that will inevitably have an effect on the transmissibility of the bug. The more transmissible, the larger number of people that will have to be protected before herd immunity could be declared.

The End and CFATS

The managers for the CFATS program did not really put an awful lot of changes in place because of the pandemic. They did modify their compliance inspection regime somewhat, including adding a remove audit process. Other than that, there were not any other real programmatic changes to the CFATS process. I expect that at some point we will see the Office for Chemical Security (OCS) announce that those inspection regime changes would be terminated.

Unofficially, OCS let the covered chemical facilities know that they understood that there were going to be process modifications made by facilities to cope with the staffing issues associated with the running of their facilities. In some cases, those changes were coordinated with chemical security inspectors (CSI) and in others not. In any case OCS accepted the reality of the situation and essentially turned a blind eye when those changes had minor impacts on the site security plans (SSPs) that facilities had negotiated with DHS.

I doubt that we will see any centralized notifications that those facility led changes are no longer acceptable. Rather, I think that contact will be made by CSI and they will work with facilities to transition back to where their SSPs were before the pandemic struck.

The COVID Reality

One thing is becoming increasingly evident, COVID-19 will be with us for quite some time, if it is ever in fact eliminated. We are seeing people previously infected with the virus becoming re-infected. The rate is relatively low at this point, but how much of that is because the potential rate is low and how much is related to the protection provided by social distancing and mask wearing has yet to be determined.

Additionally, we are seeing a small number of people who were successfully vaccinated becoming infected. This is not unusual in any vaccination program. There is just too much variability in people’s immune systems to achieve 100% success rate.

As I mentioned before, we are continuing to see mutations within the virus producing different strains. So far, there has not been a strain publicly identified that is significantly changed to be able to infect large numbers of vaccinated people. It would seem inevitable, especially with the huge number of new infections that we are seeing in India and South American, that such mutations will arise. The more infections that occur, the more the virus will mutate.

All of this is going to mean that facility management is going to have to plan for local outbreaks of COVID-19, especially in areas of the country with higher non-vaccination rates. Since management has a pretty good idea of the potential effects of such outbreaks based upon their COVID experiences, they should be able to come up with a reasonable plan to respond to such outbreaks.

I would not be surprised to see OCS mandate that facilities develop a pandemic/epidemic response plan under Risk-Based Performance Standard 14, Specific Threats, Vulnerabilities, or Risks. Taking a hard look at what worked and did not work in the last year, facilities should not have too much of a problem developing such a response plan. The approved plan should be able to be implemented by the facility with notice to OCS or when directed by OCS.

Such a response plan would be developed and approved in much the same way that any revision to the facility’s SSP is done. Facilities would come up with their proposed plan and negotiate an approve through OCS. It would then become an inspectable part of their SSP during compliance inspections.

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