CFATS Update – October 1st

As I mentioned earlier, the folks at DHS Infrastructure Security Compliance Division (ISCD) published their October 1^st status update of the CFATS program. While this is very late in the month, I think we can excuse the tardiness since first half of the month DHS was shuttered due to the federal funding fiasco.

The details included in this report all come from the period just before the F³ so this covers a period of 20 operational days (Labor Day off). The data shows continued increases in the number of authorized and approved Site Security Plans; this is shown in the first graph.

While that shows an apparent steady rate of approvals, a more detailed analysis shows a different story. The rate of site security plan authorizations have dropped off drastically while there was a significant increase in the daily rate of SSP approvals. The second graph shows the details; including the fact that the total number of combined SSP actions was a little below the rate from August.

 

The total number of SSP approvals now stands at 348; still less than 10% of the 4,248 facilities currently in the CFATS program. The authorized SSPs now total 747 or about 18% of the total. At September’s approval rate it will take 812.5 days, or 162.5 weeks (@ 5 days/week), or 3.25 years (@ 50 weeks/year) to get all of the current SSPs approved.

As always I have to remind readers that none of these approvals are final since no facility has been able to complete their planning for the personnel surety program requirements of Risk Based Performance Standard (RBPS) # 12. When ISCD gets their terrorist screening program in place, then all of these facilities with ‘approved’ SSPs will have to get their updated personnel surety programs reviewed and fully approved. This should not take a great deal of time to upgrade the current ‘almost approval’ to full approval.

BTW: The September Update (for actions taken in August) is no longer available on the Chemical Security page and was not subsequently moved to the CFATS Knowledge Center. Fortunately the old link still works.

CFATS Deliverables

It has been over a week now since the end of the federal funding fiasco and I think we can assume that the DHS ISCD folks are now back on track with their continuing implementation of the CFATS program. Here is a short list of output from ISCD that I would like to see in the coming weeks and months.

• November CFATS Status Update will be due soon;

• 30-day CFATS Personnel Surety Program ICR;

• Proposed revisions for Appendix A (for Chemical Safety and Security EO – 11-5-13 Deadline);

• Report on CFATS data sharing with SERCs, TEPCs, and LEPCs (for Chemical Safety and Security EO – 11-5-13 Deadline);

• Report on CFATS data sharing with EPA and OSHA (for Chemical Safety and Security EO – 11-5-13 Deadline);

• NPRM for Ammonium Nitrate Security Program; and

• Final action resolving ‘temporary’ agricultural producer’s exemption for Top Screen.

I had included the October CFATS Status Update when I initially wrote this, but ISCD was faster than my posting. They have just published a link to that update on their Critical Infrastructure: Chemical Security web site. I’ll have more on that this evening.

Now those are all things that are supposed to be in progress. Now for some innovative ideas that I would like to see suggested by ISCD:

• Proposal for alternative methods of certifying Site Security Plans for Tier 3 and Tier 4 facilities;

• Proposal to tie CFATS to security programs for truck and train transportation of hazardous material, particularly COI;

• Proposal to identify other potential CFATS facilities based upon CFATS facility customers and vendors of CFATS COI;

I’ll keep an eye out.