DHS Official: CFATS Program More Important Now Than Ever

The Chemical Facility Anti-Terrorism Standards (CFATS) program is more important now than ever.

That was the message Wednesday from Sue Armstrong, director of the Department of Homeland Security’s Infrastructure Security Compliance Division, in her update of the CFATS program, which requires all high-risk chemical facilities to perform security vulnerability assessments and develop and implement site security plans that meet 18 risk-based performance standards established by DHS.

The program celebrated its four-year anniversary of being signed into law just more than a week ago. And, according to Armstrong, speaking at ASIS 2010 at the Dallas Convention Center, all indicators suggest that awareness of the program is higher now than in previous years --  even as the department’s implementation of its strategy continues to evolve, creating a need for more outreach to the 4,776 facilities that must comply with its regulations.

“CFATS exists for a very good reason, and that is because the threat to our country is very real,” Armstrong said, adding that terrorist factions already are within U.S. borders, where they’re being radicalized domestically first before going to other countries for further training and support. “For those of you who aren’t aware, the U.S. intelligence community has changed its estimate of that threat. . . . We are in a new threat environment domestically, and the CFATS program is here to protect our communities.”

Armstrong said that, unlike ASIS update sessions in previous years, ISCD now is “on the ground, doing inspections,” having recently filled its ranks with 92 inspectors who are roving the country in all 50 states.

She said the division has received 3,669 site security plans to date and has completed its review of 220 of those plans. Meanwhile, the division has several notices of proposed rulemaking on the boards and is instigating listening sessions with stakeholders across the country. Also, ISCD has launched an online site dedicated to training, assessment, and top-screening assistance, as well as a CFATS “Help Desk” line at 1-866-323-2957.

Dan Walters, CPP, manager of Security & Environment Risk for Terra Industries, joined Armstrong at the podium to offer a private sector perspective on implementing and maintaining a CFATS-compliant program. He recommended that even if facilities do not yet have a site security plan, officials need to review their top-screens, which are questionnaires that enable DHS to perform a basic consequence assessment that results in a facility being preliminarily considered high-risk and placed in a preliminary tier.

“Treat your plan as if it were a regulatory compliance document,” Walters said. “Develop a separate security plan to lay out requirements of those with security responsibilities.” He added that facility managers should calendar their plans with trigger points based on such elements as training audits, drills, and document retention strategies, and then adhere to those plans. “Whether you have a 3-year or 6-year document retention plan, stick to the plan. If you’re not required to keep the document after that time, don’t keep it,” because if you do, you won’t be in compliance, he said.

Walters also advised managers to conduct incident investigations of all security incidents and to notify either DHS or the FBI -- or a host of other agencies -- when incidents happen, and to watch for changes to either the CFATS rule or the Appendix A list, which Armstrong said ISCD has already initiated a review on.

Finally, Walters said, “When in doubt, utilize the CFATS Help Desk,” which can refer managers to inspectors and staff and offer direction to training modules online.

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