Sunday, July 11, 2021

IOD and OCS in Conflict?

Back in April I wrote a blog post on CISA’s Integrated Operations Division (IOD) and their oversight responsibility for the local chemical security inspectors (CSI) and the potential conflicts that could arise between the goals of that organization and CISA’s Office for Chemical Security which is responsible for the management of the Chemical Facility Anti-Terrorism Standards (CFATS). I recently received another response (the first was here) from a different reader which may indicate that there is an actual conflict in one or more of the regional offices.

A long-time reader with connections to the program (whom I am not naming) asked:

“What if IOD doesn't support the overall success of the CFATS program. (an end goal of dismantling)?”

I have not asked for any details at this point, so I am not sure if this question reflects an actual conflict or if it is more of a theoretical condition. I will discuss the potential ramifications in both ways.

Theoretical Look

It is not unusual for dual track management of a remote workforce to have divergent goals. In a case like this where we have a workforce management organization like IOD, that organization is concerned with office overhead costs, workforce hours and overtime limits. This will frequently conflict with program management objectives that are focused on trying to ensure that technically complex inspections and reporting requirements are met. Senior chemical security inspectors are going to see the most pressure from trying to meet these conflicting management requirements.

Because of their seniority and the time-in-service investment these people have, they are not likely to complain to the outside organization that is supposed to identify, track, and mitigate these types of conflicts, the DHS Inspector General. An effective IG will be cognizant of this and will take care to be watching for indicators of this type of conflict.

Actual Conflict?

What is concerning to me is the parenthetical reference to the potential dismantling of the CFATS program as and end goal. Generally, bureaucracies are not in the business of self-destruction. If the CFATS program were dismantled, the scope of the IOD mission would also be decreased. Except, we know that there was a political attempt last session of Congress to shut down the CFATS program and to disperse the CSI into the Protective Security Inspector workforce. And those PSI work through the same IOD organization.

That political move was publicly lead in Congress by Sen Johnson (R,WI) and received almost no visible support within either house. Johnson ended up relenting and voted for the three-year extension of the CFATS program. Could there be supporters of that position be in management positions within IOD? It is certainly possible, I just do not know enough about the people in the IOD management structure to make an intelligent comment about how possible.

I suspect, however, that if there were an organized attempt in DHS to switch CSI to PSI positions, that it would not be done with any overt political end in mind. It would probably be more targeted at increasing management authority of one or more regional IOD managers. There is no central program management organization for the PSI program with highly visible regulatory program to support, so IOD regional managers have more effective control over the PSI than they would over CSI because of the high-profile management of the CFATS program.

But again, this would be an IG issue to monitor and resolve.

Another Possibility

There is another, more prosaic source of possible increase in the inevitable conflict between OCS and IOD management of CSI. In January, the long-time head of the CFATS program, David Wulf, left DHS and moved up to a higher-profile job at DOJ, part of the normal progression of career manager like Wulf. The timing, however, was less than fortunate because of the lack of appointed leadership in CISA and DHS. Todd Klessman filled in as the Acting Associate Director for Chemical Security. That left the internal political balance between IOD and OCS tilted in the favor of IOD.

If that is the cause of the apparent conflict, it should be reduced with the recent appointment of Kelly Murray to fill the role of Associate Director. Ms Murray has been working in the CFATS program almost since its inception and has worked directly with the management of the CSI in earlier roles. I would expect that she would be capable of dealing with the inherent conflict with IOD.

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