ISCD Announces East Regional Meeting

This weekend the DHS Infrastructure Security Compliance Division (ISCD) announced on the Chemical Facility Anti-Terrorism Standards (CFATS) landing page that the East DHSChemSecurityTalk would be held in Philadelphia on August 2^nd. This will be the last of the three regional DHSChemSecurityTalks held this year. The first was held last week in Oakland, CA and the second will be held on July 19^th in Chicago, IL.

Additional information and links to the registration site can be found on the DHSChemSecurityTalks web page. The agenda for the East meeting is very nearly the same as the agendas for both the West and Mid meetings. As I mentioned for the Mid meeting, there is one presentation that has been changed; instead of the “DHS Soft Target Security” presentation that will be seen in Chicago, DHS will present “Countering Malicious Use of Drones” in Philadelphia.

Commentary

When ISCD initially announced these regional meetings, I wondered if they were going to supplant the annual Chemical Sector Security Summit. Last year that meeting was moved to Houston and that looked to be a move to re-energize the meeting which had seen a gradual decline in attendance over the last couple of years. And in February ISCD announced that planning was underway for the ‘biennial’ CSSS in 2019 a much-overlooked change in the CSSS program.

In many ways regional programs make more sense than a big CSSS. It changes to a one-day event which may be easier to squeeze into a corporate schedule and many of the presentations can be tailored to specific regional concerns. Unfortunately, it also reduces the number of scope of the presentations made and would seem to remove the vendor side show aspect of the CSSS.

The major draw back to these regional meetings for many folks, however, will be the backwards step in the removal of the web cast of the presentations. There are too many folks, particularly at smaller facilities, that will just not have the travel budget to attend even these regional meetings. This is why I lobbied so hard to have many of the presentations at the CSSS web cast.

I understand that presenting web casts of the presentations for these regional events might detract from attendance at the later regional meetings. That is why I was hoping to see a notice that the East regional meeting (the last in the series) would include provisions for registration for web casts. It does not. I think that this is a major step backwards for the CFATS outreach program.

It will be interesting to see if ISCD publishes the slide presentations from these regional meetings on the DHSChemSecurityTalks. While the slides are not nearly as informative as the actual presentations, they do provide a way for expanding the audience to folks who could not attend the meetings. They also provided a way for individual who do attend to bring back the information to their co-workers who are also vital players in the CFATS process.

On a slightly different point. DHS also completed their apparently ‘monthly’ tweak to many of the pages on their CFATS web site. I did not see any major new information that was worth discussing, but there was something disturbingly missing. Last month ISCD rolled out a number of Spanish language versions of some of their outreach documents. Unfortunately, there are no links to any of those documents on the CFATS web site.

As I mentioned in my earlier post, I do not really see a wide spread need for many of those fact sheets, but the Spanish language version ‘Report a CFATS Violation Flyer’ is one that certainly needs more emphasis given the increasing numbers of Spanish speakers in the industrial workforce. The failure to include a link to that on the Report a Potential CFATS Violation page (which to be fair was not updated) or the page for the actual flyer which was updated) is a mistake that needs to be corrected. And if it was important enough for ISCD to  produce the other Spanish flyers, then they should have also have had their links included in the respective pages of the CFATS web site.

Resources for Law Enforcement and First Responders fact sheet

Last week the DHS Infrastructure Security Compliance Division (ISCD) announced on their Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center the publication of a new fact sheet for law enforcement personnel and first responders. They also announced that the registration for the 2018 DHSChemSecurityTalks – MID was now open.

Fact Sheet

The new Resources for Law Enforcement and First Responders fact sheet provides a broad overview of the information that facilities are required to make available under federal programs administered by the EPA, OSHA and DHS.

As would be expected, the section on DHS information includes a mention of the IP Gateway that I mentioned earlier last week. A new piece of information is being made available in this new fact sheet; the information available to State, local and tribal government agencies (including law enforcement and first responders) on the IP Gateway includes information on all facilities that have submitted Top Screens.

Facility name and location are only protected by For Official Use Only (FOUO) rules while more detailed facility information is protected by Chemical-terrorism Vulnerability Information (CVI) rules. According to DOD rules {32 CFR 291.9} an FOUO marking is not automatically a protection against public disclosure. Those rules note that {§291.9(a)}: “If any [Freedom of Information Act] exemption or exemptions apply or applies, it may nonetheless be released when it is determined that no governmental interest will be jeopardized by its release.” CVI rules, however, provide nearly the same level of disclosure protection as federal classified information rules.

MID Registration

The event registration site provides information about the meeting that will be held in Chicago on July 19^th at the Federal Building in downtown Chicago. Registration is required, but there is no fee to attend. As with the WEST meeting in Oakland next month, there will apparently not be a web cast of the meeting.

The agenda for the MID meeting is nearly identical to the WEST meeting agenda. The one difference is the last presentation in Chicago will address “DHS Soft Target Security” instead of the “Next Steps: Joint Regulatory & Voluntary Program Outreach to Facilities” presentation being made in Oakland.

NOTE: The Chemical Sector Regional Events web site has not yet been updated to reflect that the registration for the MID meeting has been opened.