Review - ChemLock and Information Sharing

This is part of a series of blog posts looking at the potential for the authorization of CISA’s existing ChemLock program and using it as a voluntary replacement for the now defunct Chemical Facility Anti-Terrorism Standards (CFATS) program. Other posts in this series include:

• CFATS is Dead,

• Making ChemLock Safety Act Compliant – ChemLock Program Background,

• ChemLock and Tiering,

• Reader Comment – TSDB Screening for ChemLock,

• ChemLock and TSDB Screening,

• ChemLock and Risk Based Performance Standards,

• ChemLock and Chemical-Terrorism Vulnerability Information.

NOTE: Previous articles in this series have been removed from the CFSN Detailed Analysis paywall.

The CFATS program handled a lot of sensitive information that was categorized as Chemical-Terrorism Vulnerability Information (CVI). In order to limit the exposure of that information, DHS established the Chemical Security Assessment Tool (CSAT) as a secure, on-line portal for facilities to share sensitive information with the regulators and provided a secure method for facilities to receive CVI information from DHS. If the ChemLock program is going to be upgraded to serve as a voluntary replacement for the CFATS program, a similar secure information sharing system will have to be employed to protect the information sharing required to implement that expanded program.

An authorized ChemLock program could use the security information sharing tool developed for the CFATS program as the backbone for the upgraded voluntary ChemLock program and provide a means for facilities and CISA to share chemical security intelligence information. While the Safety Act certification process would be a primary incentive for facilities to formally involve themselves in the ChemLock program, a secure source of chemical security information would also provide an additional incentive for facilities to join ChemLock, expanding the reach of the voluntary program.

 

For more information about using the CSAT backbone to provide an information sharing environment, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/chemlock-and-information-sharing - subscription required.