ISCD Publishes Monthly Update – 03-05-19

Yesterday (see note) the DHS Infrastructure Security Compliance Division (ISCD) published their latest update of data concerning the implementation of the Chemical Facility Anti-Terrorism Standards Program. The numbers published show continued recovery from the Federal Funding Fiasco that affected the program in December and January.

The table below shows the activities undertaken by the ISCD chemical security inspectors in support of the CFATS program compared to the previous two months. The inconsistencies between the ‘to date’ and ‘month’ figures are undoubtedly due to accounting issues related to report timing due to the FFF.

CFATS Activities	Dec-18	Jan-19	Feb-19
Authorization Inspections to Date	NR	3913	3918
Authorization Inspections Month	18	0	14
Compliance Inspections to Date	NR	4269	4361
Compliance Inspections Month	97	3	127
Compliance Assistance Visits to Date	NR	5131	5228
Compliance Assistance Visits Month	36	0	106

The graph below tracks CFATS activities over the last year (excluding December and January because of FFF). The yellow line at the top shows the total reported activities for the month.

The table below shows the status of facilities in the CFATS program as of the end of February. The declines in ‘Tiered’ and ‘Authorized’ facilities shows the continued maturation of the program as facilities submit and have their site security plans approved. The small increase in the total number of covered facilities indicates that more facilities entered the program than exited in February, but it provides no information on the actual number of facilities added.

CFATS Facility Status	Dec-18	Jan-19	Feb-19
Tiered		137	130
Authorized		426	412
Approved		2766	2788
Total		3329	3330

NOTE: I am not sure exactly when ISCD published this data since they are no longer providing “latest update” dates at the bottom of web pages. This seems to be an increasing problem since CISA went into effect. It would seem that CISA is following the other big DHS agency, TSA, in their obfuscation of changes in web page status.

ISCD Publishes CFATS Update for December and January

Today the DHS Infrastructure Security Compliance Division (ISCD) published their Chemical Facility Anti-Terrorist Standards (CFATS) update for December 2018 and January 2019. Needless to say the Federal Funding Fiasco has had a major impact on the numbers being reported since the Chemical Security Inspectors were furloughed for 35-days straddling those two months. Sorry to say, this is going to play hell with statistical analysis.

The first table below shows the reported CSI activity data for December and January from today’s report (the November numbers come from the ISCD report in early December). The Authorization and Compliance inspection goose eggs are due to the fact that these inspections require more prior coordination than does a compliance inspection. The ‘NR’ notation means ‘not reported’.

CFATS Activities	Nov-18	Dec-18	Jan-19
Authorization Inspections to Date	3886	NR	3913
Authorization Inspections Month	14	18	0
Compliance Inspections to Date	4135	NR	4269
Compliance Inspections Month	143	97	3
Compliance Assistance Visits to Date	5065	NR	5131
Compliance Assistance Visits Month	53	36	0

The second table shows the status of covered facilities. ISCD did not report interim numbers for December.

CFATS Facility Status	Nov-18	Dec-18	Jan-19
Tiered	178		137
Authorized	454		426
Approved	2723		2766
Total	3355		3329

The sharp drop in the number of covered facilities (-26) since November is large, but not the largest two-month drop. That was -27 in June-July of 2018. Still it is rather impressive given that ISCD was not processing Top Screens for 35-days during the period and every one was kind of holding their breath until January 18^th, when the President signed the 15-month extension of the CFATS program authorization.

BTW: The CFATS landing page was updated to ‘report’ the signing of the extension.

ISCD Published CFATS Update – 11-01-18

Today the DHS Infrastructure Security Compliance Division (ISCD) revised the CFATS Statistics web page to reflect data from October 2018. The numbers show a continued increase in the number of facilities with approved site security plans (80.2%) and a resumption of the slow decline in the number of covered facilities after slight increases in the two previous months.

The first table below outlines the activities completed by the ISCD chemical facility inspectors over the last three months. The total number of reported activities continues to show a general decline since February, but it is hard to do a reasonable statistical analysis of the trend because of a clear definition of the time frame for which the data is reported. Further, trying to assess the rate of CSI utilization from this data is complicated by the fact that the number of CSI involved in any activity varies with the complexity and size of the facility involved.

CFATS Activities	Aug-18	Sep- 18	Oct-18
Authorization Inspections to Date	3822	3854	3875
Authorization Inspections Month	68	35	25
Compliance Inspections to Date	3819	3891	3995
Compliance Inspections Month	78	71	106
Compliance Assistance Visits to Date	4749	4897	5008
Compliance Assistance Visits Month	158	126	121

The second table below shows the status of facilities currently covered by the CFATS program. The recent two-month uptick in the number of covered facilities (the ‘Total’ line in the table) has been an anomalous in the history of the program; generally speaking (with notable exceptions) facilities have a number of economic incentives to minimize their chemical security risk through reducing the number of DHS chemicals of interest (COI) on the facility or reducing the maximum inventory quantity of those COI remaining.

CFATS Facility Status	Aug-18	Sep-18	Oct-18
Tiered	218	211	205
Authorized	562	493	456
Approved	2586	2665	2701
Total	3366	3369	3362

Still missing from the monthly reporting (and at this point this is practically a pro forma comment) is any information on the compliance rate for facility inspections.

ISCD Publishes CFATS Update – 10-03-18

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) published their monthly The number of facilities in the program continued the slight increase we saw in the previous month and there is continued, long-term improvement in the number of facilities with approved site security update of the Chemical Facility Anti-Terrorism Standards (CFATS) implementation statistics. plans.

Facility Status

The table below shows the reported status of facilities covered under the CFATS program. The decline in the number of Tiered and Authorized facilities continues to reflect the expected movement of facilities through the SSP submission and approval process.

CFATS Facility Status	Jul-18	Aug-18	Sep-18
Tiered	213	218	211
Authorized	618	562	493
Approved	2531	2586	2665
Total	3362	3366	3369

ISCD Activities

The table below shows the reported activities that the DHS chemical security inspectors (CSI) from ISCD undertook in the support of the CFATS program in September.

CFATS Activities	Jul-18	Aug-18	Sep- 18
Authorization Inspections to Date	3768	3822	3854
Authorization Inspections Month	44	68	35
Compliance Inspections to Date	3752	3819	3891
Compliance Inspections Month	59	78	71
Compliance Assistance Visits to Date	4598	4749	4897
Compliance Assistance Visits Month	103	158	126

It is hard to judge the fluctuations in the number of activities undertaken by CSI. Each facility is different and would be expected to require differing amounts of time and number of inspectors involved to complete the reported inspections or visits. Additionally, ISCD does not report on the different types of training activities that its personnel require, nor does this report show changes in the number of CSI employed by the program.

ISCD Publishes CFATS Update – 09-07-18

On Friday the DHS Infrastructure Security Compliance Division (ISCD) published their latest update of statistics on the implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) program. This month the figures indicate that more facilities were added to the program than left and there was a significant increase in the number of facilities with an approved site security plan.

ISCD Activities

The table below summarizes the activities that ISCD undertook to support the CFATS program.

CFATS Activities	Jun-18	Jul-18	Aug-18
Authorization Inspections to Date	3713	3768	3822
Authorization Inspections Month	66	44	68
Compliance Inspections to Date	3684	3752	3819
Compliance Inspections Month	131	59	78
Compliance Assistance Visits to Date	4463	4598	4749
Compliance Assistance Visits Month	113	103	158

We see a significant increase in activities over the low of the previous month. This would tend to indicate that last month’s lower than normal numbers were probably related to vacations and the 4^th of July holiday.

Facility Status

The table below shows the status of facilities in the CFATS program at the end of the month (my best guess of the effective date of the data).

CFATS Facility Status	Jun-18	Jul-18	Aug-18
Tiered	216	213	218
Authorized	623	618	562
Approved	2528	2531	2586
Total	3367	3362	3366

The data shows the first net increase in the number of covered facilities since February. From the data presented it is not clear if that increase is due to an unusual number of new facilities submitting Top Screens (probably mainly in July) or if there were fewer facilities exiting the program due to changes in their COI or security posture.