Monday, January 8, 2018

ISCD Publishes CFATS Update – December 2017

Today the DHS Infrastructure Security Compliance Division (ISCD) updated the data on the Chemical Facility Anti-Terrorism Standards (CFATS) Monthly Update page. The new data for December 2017 shows the continued progress being  made implementing the CFATS program.

Facility Status


The table below shows the change in the current covered facility status for those facilities covered by the CFATS chemical security program over the last two months. A decline in the number of ‘Tiered Facilities’ is expected as recently tiered facilities complete their site security plans and have those plans authorized and ultimately approved.

CFATS Facility Status
Nov-17
Dec-17
Tiered
843
723
Authorized
429
493
Approved
2276
2340
Total
3548
3556

It looks like ISCD has completed the notification process for facilities to resubmit Top Screens in support of the implementation of CSAT 2.0. The increase in the number of covered facilities appears to be leveling off. Based upon program history, I would not be surprised to see the number of covered facilities start to actually decline.

ISCD Activities


The next table shows the activities that ISCD had taken during the month of December to support the CFATS program. The ‘to Date’ data reflects the total number of inspections/visits that have been completed since the CFATS program began.

CFATS Activities
Nov-17
Dec-17
Authorization Inspections to Date
3102
3132
Authorization Inspections Month
70
49
Compliances Inspections to Date
3065
3112
Compliances Inspections Month
87
77
Compliance Assistance Visits to Date
3723
3799
Compliance Assistance Visits Month
92
100

ISCD continues to have problems with reconciling the reported number of monthly inspections/visits and the number of those visits to date. Looking at the ‘Authorization Inspection’ data we see an increase of just 30 inspections done since the last report while reporting that there were 49 inspections completed in December. We see a similar difference in the compliance inspection and compliance assistance visit data.


In the past the discrepancy has been the other way; with a larger increase in the cumulative inspections than was reported as having been conducted. I had suggested in earlier blogs that these earlier data oddities could be explained by a number of facilities leaving the program or failing inspections. Neither of those explanations would explain the differences seen this month.

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