Review – Chemical Security Inspector Reduction in Force – Part 4

I have been talking about the upcoming reduction in force of CISA’s Chemical Security Inspectors (CSI) this week. This will probably be the last post in this series of free posts in the series so I thought that I would try to outline what I would like to see happen. The earlier posts in this series include:

CSI RIF,

Chemical Security Inspector Reduction in Force – Part 2, and

Chemical Security Inspector Reduction in Force – Part 3

Too Late to Fix

To start with, I learned today that the CSI have been given until Monday to make their decisions about whether to take the offered ways to quit (making DHS look better than firing them would), or to stay around long enough to actually get their reduction in force (RIF) notices that everyone knows are coming. Neither option is great. Take the deferred resignation and get paid (with benefits) through the end of the fiscal year, but resignations mean that there will be no unemployment benefits. Get RIFed and they are eligible for unemployment benefits, but at much lower pay than they have been receiving. Federal medical benefits also disappear; fortunately, Obama Care is now available, not great, but better than what was available the last time I was laid off.

 

To see the alternatives that would provide a longer-term solution to the job situations for CSI and the security support for chemical facilities, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/chemical-security-inspector-reduction-7ca - free content.

Review – Chemical Security Inspector Reduction in Force – Part 3

Yesterday I published a guest post over on my CFSN Detailed Analysis blog by a CISA Chemical Security Inspector about the role of the CSI in the Chemical Facility Anti-Terrorism Standards (CFATS) program and their pending abolition in the current restructuring of the Cybersecurity and Infrastructure Security Agency. I thought that that letter was important enough that it should stand on its own before I added my two cents worth.

First, I want to clear up a mistake on my part in the introduction of yesterday’s post. I stated that the post was written by CSI that had “recently received their reduction in force notification.” What they had received from CISA was an advanced notice about the reorganization of CISA that has been described elsewhere. The actual RIF notices have not yet been sent out. What they were told was that the CSI were no longer required. About the only thing that can stop that is action by Congress, which is, unfortunately, unlikely to happen.

The bulk of my comments on that guest post are going to be published on CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/chemical-security-inspector-reduction-faa - again as a free-to-all post.

Moving Forward

In the face of the mass layoffs at so many federal agencies, many would ask why I would take up the case of these eighty or so CSI that are most probably facing their own layoffs. The simple answer is that I have been advocating for them and their compatriots for the last 16 years or so and I am not going to stop now. More importantly, I have a solid understanding of what CISA and DHS are going to lose if these CSI are going to be let go. This is a valuable resource that CISA will eventually deeply regret losing.

Chemical Security Inspector Reduction in Force – Part 2

I published a non-paywalled article over on CFSN Detailed Analysis, it is a long-form letter from a CISA Chemical Security Inspector that was better suited to that format. Please, go and read it there.

CSI RIF

I got my first report today that the Chemical Security Inspectors (CSI) are now in the reduction in force spotlight. Apparently, letters started going out Friday letting CSI know that their services were no longer needed by the federal government. While the overall numbers are not as large as those being seen at some other agencies (the maximum staffing was about 160 individuals) these are folks that were providing key support for the expired Chemical Facility Anti-Terrorism Standards (CFATS) and the newer ChemLock program. That provides a special connection to me and most of the readers of this blog.

These individuals have a unique skill set that for the most part has been developed in the field over the 15+ years that the CFATS program was in force. They have an unusual appreciation for the peculiar security needs of a wide range of chemical facilities, from chemical refineries to small chemical warehousing operations, from research facilities to farm supply stores. They have seen what works and what does not. Hopefully all will be able to quickly find work advising industry on chemical security matters. NOTE: If you have openings, please let me know, I will add them to my daily ‘Short Takes.’ post.

At this point, I do not know how deep the reduction in force is for CSI. The ChemLock program does not need near as many CSI as did the CFATS program. And I am not sure that ChemLock will survive the CISA restructuring, since that program was never specifically authorized by Congress. Since the CSI were not technically a part of the CFATS program (they worked for the CISA regional offices instead of CFATS office). I had hoped that CISA would realize that their unique training would act as a valuable supplement to the similarly small number of Protective Security Advisors (PSA) and Cyber Security Advisors (CSA) that have been on the road providing security support to critical infrastructure organizations.

At this point I wonder what would have happened if Kelly Murray had spent as much time trying to get ChemLock authorized as she did trying to get CFATS reinstated. It was obvious to me early on that the opposition of Rand Paul was not something that was going to be overcome by industry pressure; he is a true believer that knows when he is right and is not likely to change his mind. Kelly gave her all to put as much pressure as she could, but it was never going to be enough. To be fair, that may not have been her decision to make, but it was her face and voice that will be remembered. 

Reader Comments – Online CSI Applications

Over the weekend I had two comments from apparently different anonymous readers (here and here) about an error in my Friday post about Chemical Security Inspector (CSI) jobs listed on USAJobs.gov. In my post I complained about having to fax the job application into the site rather than being able to apply on-line. Both readers responded that you could apply for the job on-line. After actually trying the on-line application process I found that they were correct.

I misunderstood the portion of the instructions relating to the submission of “A complete Assessment Questionnaire” in the Required Documents portion of the job listing (the other job listing has already closed). The only other reference to that questionnaire in the listing is found above that requirement with a link to a manually completed document that is required to be faxed to the number provided. After working through the on-line application it is clear that the ‘Assessment Questionnaire’ is included in that application a format that is much easier to deal with.

As a recent expert in the field of on-line job applications I found the on-line application for this job to be a tad bit more detailed than most application that I have completed, but not onerously so. I am still disappointed in the job listing itself as it is way to bureaucratic for my taste, but I suppose that is to be expected for what is after all a bureaucratic job.

BTW: The opening that I explained above that had been closed? Well it has actually been replaced with an updated version that does not close until Thursday. So there are still two current listings for Chemical Security Inspector with a total of 21 open positions between them.

21 CSI Job Openings

There are currently two USAJobs.gov listings for Chemical Security Inspectors with DHS National Protection and Programs Division (NPPD). Between the two listings there are 21 vacancies that NPPD is trying to fill in the CFATS inspection program at various locations around the country. These listings stay open for a very short time period and close next Tuesday and Thursday respectively.

Qualifications

For the entry level (GS-09) position you must either have a Masters degree in Safety Engineering, Industrial Hygiene Inspection, Chemical Engineering, or Process Safety Engineering or 1 year of experience in:

• Conducting or assisting with on-site inspections and audits of regulated facilities to determine if violations have occurred;

• Conducting investigations using accepted inspection, enforcement, and investigative procedures; and

• Preparing reports to both private and public sector personnel on security compliance and enforcement matters.

Competencies

The job notices report that your qualification will be evaluated against the following competencies:

• Knowledge of and ability in conducting on-site physical inspections, documentary reviews, personnel interviews, and site vulnerability analysis of chemical facilities;

• Knowledge of and ability to review and evaluate the physical, personnel, information and cyber security plans and countermeasures of chemical facilities against risk based performance standards;

• Ability to communicate effectively orally; and

• Ability to communicate effectively in writing.

Salary

The salary ranges for the two positions are listed as:

$48,403.00 - $90,129.00

$48,403.00 - $84,800.00

Commentary

I have had extensive experience filling out employment applications over the last nine months and I must say that the application process through USAJobs.gov is one of the least professional, most complex and least professional (I know, I said that twice, with good justification) that I have ever seen. The first thing that you have to know is that it cannot be completed on-line. You have to print out the forms, fill them in by hand, and then fax them in to the application office.

I have not actually completed filling in the forms (since I do not meet the qualifications for entry level for either of these positions), but it looks like this could take a couple of hours. And the site clearly states that if the application is not complete in every detail, it will not be considered. In my opinion, if you can complete the application process in one go, you are fully qualified for the job on bureaucratic grounds alone.

If you are qualified for the positions, and have a desire to help chemical facilities complete the CFATS process to reduce their risk of terrorist attacks, please apply. It may sound corny, but the country really does need you.

BTW: Vacancies will be filled as funding permits – This is always a caveat for federal jobs.

CSI Dissatisfaction

I have been hearing some rumblings that there may be some increasing tensions between the CFATS chemical security inspectors (I hate this acronym, please change the name to chemical facility security inspectors) and the Infrastructure Security Compliance Division (ISCD) headquarters. It seems that there is at least an impression that HQ is increasingly overriding SSP approval recommendations made by CSI.

Now we have to remember that there will always be a little bit of a disconnect between field operatives and headquarters personnel in any organization. While the over-all mission of the organization may be the same, the focus of field personnel and upper management will always be somewhat different. I have seen this in every organization that I have worked in in almost 30 years in industry and 15 years in the military (oops that doesn’t add up as I can’t be more than about 40 years old).

The complaint is also more than a little surprising since there is a great deal of pressure on the management of ISCD to get the SSP authorization and approval process completed. Congress, the regulated community and the security press all want to see the approval process completed in a much shorter period than the current authorization and approval rate would seem to indicate is possible. One would tend to think that the ISCD HQ would be more likely to over-ride field organizations in the direction of approval rather than disapproval.

Now I have talked to Director Wulf and he appears to be focused on expeditiously, but appropriately moving the authorization process forward. And the general comments I am hearing from the field seem to indicate that the CSI realize this and support his efforts. The complaints have more to do with the involvement of the intermediate leadership in that process.

From where I sit, I cannot tell if there really is a problem yet. Individual complaints and observations may just be colored by isolated personal observations and interactions and may not reflect overall organizations issues. But, ISCD managers need to remember that the perceptions of the folks at the operational end of the organization will affect the way that they do their jobs, even if those perceptions do not reflect reality.

David Wulf took over control of ISCD when there was a serious disconnect, even outright conflict, between the field operations folks and HQ. He and his staff have worked hard to correct many of the problems that were the source of that conflict. But, they need to remember that, amongst all of the other problems they deal with on an ongoing basis, they cannot consider the communications with the filed a solved issue. This is something that will require an ongoing focus and continued effort.

SSP Review – Paperwork or Footwork

I recently had an interesting conversation with a reader associated with ISCD (who will remain nameless for obvious reasons). One of the topics that came up was how ISCD goes about approving site security plans.

The Approval Process

Now ISCD is a little vague on the details of the process that they use to review a submitted SSP, but the basic outline is this:

An initial review of the submission is done at ISCD HQ. This includes a rough overview to ensure that all of the required information is included. Then it gets divided up and sent off to various subject matter experts (SME) for a more detailed review of the submission data. ISCD HQ may ask facility for missing information or clarification of inadequate information.

Chemical Security Inspectors (CSI; I still hate that name, Gil Grissom comes immediately to mind) make a series of visits to the facility (Pre-authorization inspection and authorization inspection are generally the minimum) to actually look at the facility, clear up any misunderstandings about submitted information and to actually look at the facility to ensure that the submitted data bears a good resemblance to what is happening on the ground. The CSI will make a recommendation about the status of the SSP.

A final review is done at ISCD HQ and based on some sort of review of SSP submission data, CSI recommendations and HQ subject matter experts recommendations a ruling is made on the SSP. The good ones get an authorization letter and get put on the list for an approval inspection. The ‘bad’ ones go back into the submit data, review, inspect, and review cycle until they get put into the authorized list. Uncooperative facilities can get transferred into the civil enforcement process, but I haven’t heard of any being placed in that track in the SSP process.

Which Review Gets the Most Weight

The question that came up in the conversation that I mentioned earlier is how do you weight the two different types of reviews, the ones conducted by CSI and the ones conducted by SME? Or to put it another way, when there is a conflict between the two types of recommendations, who does the final authorizing authority side with?

Now both reviews are valuable and necessary, but if there is a conflict in the conclusions reached in the two types of review, I would certainly have to side with the people on the ground. Since they are the ones that had a chance to walk the facility and actually look at what was on the ground, they should have a better appreciation for both how seriously the facility is taking their security program, how well the folks are actually trained to fulfill their security roles and how well the security measures mesh together in a security zeitgeist.

This is particularly true for facilities that do not use an alternative security plan (ASP) like the ACC ASP. As I have noted on a number of occasions, the current SSP questions are really inadequate for the purpose of eliciting adequate information allowing for a full SME review of the SSP. Facilities must use the free form description blocks to be able to adequately describe all of the necessary characteristics of a particular security measure.

 Facilities that have good writers or consultants that know what verbiage the DHS SME are looking for will not have a problem with giving those SME adequate information to get an SME approval recommendation. A favorable review in this case may clear an inadequately secured facility.

A facility without a good writer that is versed in security matters or, lacking that, a well-connected contractor will be at a severe disadvantage in this HQ review process. They will not be able to paint the proper picture in the eye of the SME that will result in a favorable review.

Boots on the Ground

At one point in my Army career I was responsible for doing security inspections of subordinate units; physical security, classified document security, communications security and the like. I wasn’t long in that job before I could pretty much tell you what my inspection report to the Commander would be like within seconds of entering the facility. You could see all of the little signs that indicated that the unit either took their security requirements seriously or were just going through the motions.

I’m sure that CSI going into a new facility can tell the same thing. And they will see the little things that will never make it into written descriptions of the security measures. Thing like does the facility use a single vertical support for the barbwire outrigger on corner fence posts or two  45° outriggers to carry the barbwire around the corner.

Boots on the ground, particularly well trained boots (and more about that later) will be able to provide a much better overall evaluation of the actual SSP on the ground. That certainly does not obviate the need for SME reviews of the submitted written record, but the role of the SME should be to provide the CSI with pointers of specific things to look at when conducting the inspection.

Out of Balance

It seems like the balance may have been shifting recently to favoring the SME evaluation over the CSI evaluation. At this particular point in the SSP review process this is a particularly inappropriate time for such a switch. Most of the largest, most dangerous facilities have completed their initial process. As a rule those facilities had either trained security management personnel on staff, or could pay for the support of well connected contractor.

We are now beginning to move into the inspection of the typically smaller, less dangerous facilities that generally do not have on staff security management personnel nor are they usually going to have the money to hire the most experienced contractors. They are going to have a more difficult time getting adequate descriptions of their security measures to the SME.

As long the ISCD SSP approving authority is willing to weight the acceptance of SSP recommendations to favor the CSI, these smaller facilities will get a fair assessment of their security strategies. If we are seeing the reported shift back to favoring SME recommendations, then we are going to see a slow-down in the authorization and approval process.

More ISCD Job Openings

I just received an email from USAJobs.com about two sets of job openings in DHS Infrastructure Security Compliance Division (the CFATS people). They have multiple job openings for Chemical Security Inspectors (and I’ve been calling them Chemical Facility Security Inspectors to avoid the ‘CSI’ tag) and Supervisory Chemical Security Inspectors.

Locations

The job listings say that there are openings in multiple locations for each of these positions.

For the CSI there are “many” openings in the following cities:

• Memphis, TN
• Fort Snelling, MN
• Madison, WI
• Albuquerque, NM
• Buffalo, NY
• San Francisco, CA
• San Antonio, TX
• Brea, CA
• Pittsburgh, PA
• Louisville, KY

For the SCSI there are “few” openings in the following cities:

• Grand Prairie, TX
• Houston, TX
• New York, NY
• West Chester, PA
• Tallahassee, FL
• Saint Louis, MO
• Baton Rouge, LA
• Phoenix, AZ
• Knoxville, TN
• Seattle, WA
• Kansas City, MO
• Portland, OR
• San Francisco, CA
• Brea, CA
• Richmond, VA

Does it seem kind of odd that there are openings in more cities for SCSI than for CSI? Something is odd there; I’ll try to find out what. At least it seems that there are more actual openings (many vs few) for CSI than for SCSI.

Too Many Vacancies

Now there are a ‘few’ vacancies in each city for SCSI. So does that mean 45 (few – 3, 3*15 cities)? The many vacancies for SCSI  could mean 40 (many – 4, 4*10). That would be 85 positions out of about 160 authorized. This is way too many folks missing from the ranks. I seem to recall hearing 120 inspectors on hand in various hearings. Have we been losing that many folks because of the problems at ISCD?

CSI Qualifications

The CSI lists slightly different qualifications for people being hired at the GS-09, GS-11, GS-12, or GS-13 levels. The GS-09 (entry level) qualifications include one full year of specialized experience comparable in scope and responsibility to the GS-07 level in the Federal service (obtained in either the public or private sectors) that involved knowledge of:

• Homeland security;

• Infrastructure protection;

• Information security;

• Intelligence and law enforcement information; and

• Information analysis, along with knowledge of analytical and investigative techniques.

Alternatively an applicant could have a Master’s degree in one of the following qualifying fields:

• Safety Engineering;

• Industrial Hygiene Inspection;

• Chemical Engineering; and

• Process Safety Engineering.

Interestingly, a degree in chemistry or criminal justice without additional course work in one of the above fields would not be qualifying. Combinations of the experience and educational requirements can be used. Obviously I’m hitting the highlights here, see the job listing for more details.

SCSI Qualifications

As one might expect the qualifications for the SCSI position are a bit less complicated. The applicant must have one full year of experience at the GS-13 level (in the public or private sector) that includes:

• Evaluating subordinate chemical inspector preparation, performance, and reporting on chemical facility inspections;

• Reporting on chemical facilities by utilizing the Chemical Facility Anti-Terrorism Standards (CFATS); and

• Supervising the work performance of other chemical facility inspectors.

Ammonium Nitrate Security Program

There is an odd difference between the descriptions of the two job positions; even taking into account that one is a supervisory position and the other is not. The CSI Job Summary section of the job listing notes in addition to doing CFATS inspections the job would require the CSI to “plan, organize, schedule and conduct on-site inspections of ammonium nitrate facilities”. The SCSI Job Summary does not say anything about CFATS but does provide a similar mention of inspections at ammonium nitrate facilities.

As I mentioned in an earlier blog, DHS does not plan to issue the Ammonium Nitrate Security Program final rule until December and I wouldn’t be surprised if it was in 2014 or even 2015 when the final rule was actually published. But, these job listings both seem to indicate that DHS is ramping up now for that enforcement effort.

Need for Good Folks

Well, the CFATS program, for all of its faults, is an important program that needs good people. If you are interested (or know someone that should be interested, tell them) get your applications in through USAJobs.gov. The CSI jobs close January 30^th and the SCSI jobs close January 29^th.