ISCD Reorganization

Effective tomorrow there will be a significant reorganization of the Infrastructure Security Compliance Division (ISCD), the organization within NPPD that runs the CFATS program. Rick Diggers, the new acting director (as of December 20th) has directed the reorganization that will place the inspection force under his direct control, and moving all engineering, analysis, document review and industry relation work to the Compliance Branch (currently headed by a new acting branch chief, reportedly with an industry PR background). This greatly reduces the work load (to almost non-existent by some reports) of the three remaining branches of the Division.


Supposedly Diggers was brought into shake up the Division because of delays in CFATS implementation and the slow development of the ammonium nitrate regulations. It seems that the CFATS delays extend beyond the slow completion of SSP approvals. Other delayed areas include program development for:

• Agricultural production facilities currently under a ‘temporary Top Screen exemption’ since 2008;
• Reviewing and approving alternative security programs; and
• Reviewing and approving requests for re-determination (over 600 pending).

Rumors abound that the reorganization was directed and guided by Sue Armstrong, the former Director of ISCD and currently Assistant Secretary for NIPD where she still retains responsibility for ISCD. If true, this would be interesting since the problems date back to her tenure as Director. Actually it seems that many of the current problems being experienced by ISCD, including the personnel issues that I’ve discussed before, date back to period when Sue ran the Division and are only now coming to public view.

Since Diggers is statutorily limited to a 120-day tenure as ‘Acting Director’ and NPPD is currently reviewing applications for the permanent director, it seems that these changes may only last until a new director is hired. Since Diggers has never managed a program of this size (either in manpower or budget) before, he is unlikely to remain in the ISCD Director position.

I don’t know enough about the internal workings of ISCD to be able to truly gauge the effectiveness of these changes, but it does seem to me that putting the Regional Commanders of the inspection force under the direct control of the Director is unworkable. Span of control issues, Digger’s lack of knowledge about the CFATS program, the chemical industry (he has an intel background), and security programs in general make it unlikely that he will be able to effectively manage the inspection force.

Oh, well. I guess we’ll just have to wait and see how this works itself out. I’m getting more and more concerned though that this program is heading the way of so many of poorly managed and supported chemical safety programs. Fortunately, it seems that the terrorists are even more poorly organized and managed. Let’s hope that their lack of organization stays worse than that of ISCD.