I was recently at the largest security tradeshow in the county. It’s the American Society of Industrial Security, also known as ASIS. The show is held every year in September or October — this year in Dallas. The educational conference program covers a wide variety of security topics and two of the sessions were devoted to CFATS and chemical security. Sue Armstrong, director of the Department of Homeland Security’s Infrastructure Security Compliance Division, spoke at the first session.
Armstrong gave an update of the CFATS program and as you would suspect she concentrated on the Security Site Plan (SSP) process, since most facilities are now working on that part of the mandate. CFATS has just turned four years old and Armstrong’s presentation made it clear that DHS has learned some lessons along the way. She emphasized the department’s willingness to work with facilities and businesses toward compliance and the importance of preauthorization inspections.
Armstrong did point out that many facilities submitted an initial SSP that did not go into the needed detail for DHS to approve. Apparently some companies were reluctant to put too much information into the plans at first, and DHS had to go back and work with those facilities to get the information they needed to determine compliance. That’s something we have discussed before regarding SSPs — facilities have to list all assets and go into detail on procedures and processes, so that DHS can determine if they provide an adequate level of security.
As of Oct. 4, Armstrong said, DHS had received 3,669 site plans and has reviewed more than 220 of those with three SSP authorizations. As of Oct. 1, the department has also done 119 preauthorization inspections where they’ve gone in to work with facilities on compliance issues prior to final review. Armstrong said that facilities should expect an on-site inspection to take a week.
The Infrastructure Security Compliance Division (ISCD) has issued two sets of administrative orders to facilities that have failed to submit their SSPs within 120 days of receiving final tier notification — an indication that DHS means business and wants facilities to keep moving forward through the process. Orders were issued to 18 facilities in June and another 21 in August. At this point all 39 facilities have submitted an SSP.
Armstrong also said that DHS is placing more inspectors in the field. The department has filled 173 of 268 staff positions. Of those 92 are field inspectors there to help with preauthorization inspections. She emphasized once again that putting together an SSP takes a team. It cannot be handed off to one person in the facility. It needs to include compliance, human resources, security and legal team members.