DHS Begins Issuing Tiering Letters Based Upon CSAT 2.0

Today the DHS Infrastructure Security Compliance Division (ISCD) updated their “Critical Infrastructure: Chemical Security” web site to add language announcing that ISCD had begun “issuing tiering determination letters to facilities that were assessed using the enhanced methodology”.

The “Tiering Methodology” web page (also updated today) noted that:

“Based on the Department’s analysis of a representative sample of tiering results, some facilities will see a change in their tiers. Some facilities that were previously not covered under CFATS will find themselves covered, and some currently-covered facilities may no longer be considered high-risk. Some of these tier changes are a result of changes to the tiering methodology, while others are the result of changes facilities have made to their businesses, such as adding new chemicals, removing chemicals of interest, or modifying storage methods.”

DHS will be holding two webinars to discuss tiering trends and to respond to questions from facilities. The webinars will be held on:

April 24^th, 2017; and

May 3^rd, 2017

There is nothing on the web site that explains what ISCD expects facilities to do; that will be included in the notification letter sent to each facility. Facilities with added DHS chemicals of interest (COI) or upgraded Tier Ranking can expect to be notified of the need to submit a new SVA/SSP. Facilities with downgraded Tier Rankings will probably be notified of the opportunity to submit new SVA/SSPs to reflect the lower security requirements associated with the lower Tier Ranking. Facilities that are being removed from CFATS coverage will be reminded that they will still be required to re-submit Top Screens if their current COI inventories increase or new COI are added to their inventories.

More on CFATS Re-Tiering Letters

Last week I wrote about rumors of ISCD sending letters to some 400 CFATS facilities advising them that their tier level had been adjusted to correct for errors in the model DHS used to evaluate the comparative risk at covered facilities. Some time yesterday DHS updated a number of web pages on the chemical security site to provide additional confirmatory details to that rumor.

Chemical Security Web Page

Starting with the Critical Infrastructure: Chemical Security page a entry in the column along the right hand side of the page for ‘Notices’ has been added with a link to a page specifically about the ‘Revised Tiering Assignments’.

That page explains the reason for the changed assignments:

“Following a DHS review of the results of one of the risk assessment tools that revealed some apparent anomalies, the Department replaced modeling data in one part of the tool, potentially affecting the tiering assignments for facilities with certain chemical holdings. DHS subsequently re-evaluated the tiering assignments for those facilities and adjusted the tiering in some cases.”

DHS goes on to assure facilities:

“None of the affected facilities will receive a higher-risk tier assignment as a result of this re-evaluation. In fact, many will be assigned to lower risk tiers or no longer be subject to CFATS regulation.”

CFATS Knowledge Center Page

As one would expect the CFATS Knowledge Center page also provides information on the issue with new information added to that page today. There is a brief note in the ‘Latest News’ section that states:

“DHS has posted a clarification regarding the June 2011 revised tiering assignments that affected a limited number of facilities covered under the CFATS program (see Articles).”

The Article mentioned in that note is article 1722, DHS Notifies Chemical Facilities of Revised Tiering Assignments. This article provides the same information as the Revised Tiering Assignments web page. That article can be exported as a .PDF document or copied into any word processing program.

Modeling Problems

I have done some very low level chemical process modeling over the years and I know how difficult it can be to get a model that accurately reflects all of the variables under consideration. It takes constant monitoring of the results of the model to ensure that it is providing reliable information. Apparently DHS has been doing just that with this very complex model.

ISCD is to be commended for not only identifying and correcting the error in the model, but also for publicly acknowledging the problem and taking the appropriate efforts to correct the impact of that problem.

It would be interesting if they would tell us how many facilities were affected and what kinds of tier level changes resulted. It appears that some facilities may have dropped off the CFATS map, and it would also be interesting to learn that number. Finally, it would be nice to know the ‘chemical holdings’ that were affected by the model glitch, but I doubt that DHS will be willing to share that information.

Facility Response

I’m sure that there will be some consternation at some of the facilities that now realize that their site security program may be relaxed somewhat due to the lower performance standards for their new tier ranking. That it may lower their costs will be a welcome relief.

Their will inevitably be some facilities that have already spent a great deal of money on security measures commensurate with their old rankings that are no longer necessary for their new status. The only good point is that they will be able to better respond to any future increase in risk due to either outside factors or changes in their processes or inventories.