I recently sat in on another webinar where DHS gave a CFATS update. This time it was Todd Klessman, acting branch chief, Policy and Programs Branch, for the Infrastructure Security Compliance Division at the Office of Infrastructure Protection. Here are the numbers as of January 2011:
• More than 38,000 initial Top-Screens received by DHS
• More than 7,000 preliminary tier notifications issued by DHS
• 4,755 facilities covered by CFATS across all 50 states
• Nearly 4,000 Site Security Plans (SSP) and Alternative Security Programs (ASP) have been received by DHS
• More than 150 Pre-authorization Inspections (PAI) have been completed by DHS
• 4 Authorization Inspections (AI) have been completed
• 63 Administrative Orders have been issued to facilities that failed to submit a Site Security Plan within the deadline (all 63 facilities are now in compliance with CFATS)
So, as the numbers indicate there is some real progress being made on CFATS compliance. There is also some great information being generated to help facilities make it through the preauthorization inspections and resubmission process.
Klessman also discussed some of the other major ongoing and planned activities. The department continues to conduct a review of CFATS Appendix A and the current list of Chemicals of Interest (COI). He indicated that the focus is on things like screening threshold quantities and mixture rules. DHS is also continuing to refine the Chemical Security Assessment Tool (CSAT) based on input from users.
Apparently, DHS is also still working with the U.S. Coast Guard on improving the harmonization and coordination of CFATS and the Maritime Transportation Security Act (MTSA). The department is also finalizing the analysis of the agricultural facility surveys. Right now, many agricultural facilities are exempt from the CFATS mandates. The department is looking at the survey to determine if that exemption should become permanent.
Klessman also reiterated the current administration’s belief that the exclusion of water and wastewater facilities leaves an unintentional gap in the CFATS mandate. The administration thinks water facilities should stay under the EPA, but that DHS CFATS tools should be used to make sure these facilities and the chemicals they use and store are secure. Of course, Klessman noted, this would be up to Congress.
One last thing that Klessman discussed was that there still may be facilities that fall under CFATS but have not submitted a Top-Screen. He said facilities need to be careful because they will eventually be identified. He said that DHS is mainly looking at submitted materials to determine which facilities fall under CFATS mandates, but he also said that the department does have other resources available including satellite images.