A Holistic Approach to CFATS Compliance

Knowing the identity of workers and monitoring their access to various operations are key capabilities required to meet Chemical Facility Anti-Terrorism Standards (CFATS). Several of the Department of Homeland Security (DHS)'s 18 Risk-Based Performance Standards (RBPS), which were formulated to ensure protection of chemical facilities, specifically mention the need for comprehensive monitoring of employee identity and control of access to critical areas.

For example, RBPS 3 specifies the need to “implement a regularly updated ... system that checks the identification of facility personnel and other persons seeking access to the facility.” Ensuring identity and controlling access to critical areas are also requirements for compliance with RBPS 7, which calls for deterrence of insider sabotage. RBPS 8 is specific to cyber sabotage, including the need to “prevent on-site or remote access to critical process controls,” such as computerized systems, disruption of which could be used for terrorist purposes.

RBPS 12 requires appropriate background checks and credentials for facility personnel and for unescorted visitors with access to restricted areas or critical assets. Specifically, RBPS 12 necessitates measures designed to verify and validate identity, to check criminal history and to verify and validate legal authorization to work. RBPS 12 also requires proper security training of facility personnel, which is another aspect of monitoring employee compliance with CFATS standards.

Taken together, the RBPS standards point to a need for a holistic approach to physical security management. Most chemical organizations operate multiple facilities across the country and around the world, some located in unstable regions. The high-risk nature of the compounds used in these diverse environments, especially in the higher-risk facilities categorized as Tier One and Tier Two by DHS, makes it imperative that they be protected against terrorists and internal sabotage.

Complying with CFATS requires multiple stages of evaluation and compliance; lack of compliance can trigger significant daily fines or even the requirement that a facility cease operations. A comprehensive approach to managing physical identities and their access across disparate physical access control systems enables a facility impacted by CFATS to meet the various RBPS standards, whether specific to identity or broader in scope.

Use of specialized commercial off-the-shelf software can unify and streamline a chemical facility's efforts to meet CFATS guidelines in many ways. Advanced software can provide a single interface to manage all identities, roles and related-area access across a global security infrastructure. Software can also perform as an integral part of facility operation, making CFATS compliance an element of daily operations rather than a separately managed project.

A software-based solution provides a flexible, scalable and secure approach to managing employees, contractors and visitors for CFATS compliance. Software can integrate with an existing physical security infrastructure while ensuring compliance with CFATS. Software can automate all processes that encompass the “life cycle” of an identity as it relates to physical security. Integration with external databases automates completion of background checks required for facility personnel and visitors. Security staff can easily design and manage multiple badge templates and enroll Transportation Worker Identification Credential (TWIC) cards centrally. A Web-based self-service interface enables end-users to be part of the credentialing process – with workflow capabilities for approval, notification, and changes, all with a complete audit trail.

A comprehensive software-based approach to identity management helps chemical facilities achieve several of the RBPS standards, including:

Screening and access control (RBPS 3), by automating condition-based access including successful background check, approval from an area owner and completion of training.

Shipping, Receipt and Storage (RBPS 5), by automating processes involved with vehicle inspection including pre-registration of shipments and real-time background checks of drivers against internal and external watch list databases.

Theft or Diversion (RBPS 6), by defining multiple controls for access to restricted areas, ensuring background checks and automating check-in/check-out processes of vehicles and drivers within a facility.

Sabotage (RBPS 7), by automating visitor management processes such as escort sign-in, access control and background verification. Facilities may also maintain their own watch list of persons of interest, such as disgruntled ex-employees.

Personnel Surety (RBPS 12), by automating background checks, including those mandated for chemical facilities.

Elevated Threats (RBPS 13), by responding to changes of threat levels with various sets of actions and outcomes.

Reporting of Security Metrics (RBPS 15), including reporting functionality with pre-built reports and customized reports for security metrics.

Ensuring compliance and providing security metrics are particular areas where a software-based system adds value. Software can help physical security practitioners define, assess and report on a variety of risks across the security infrastructure. By automating key policies and procedures, a system prepares organizations to prevent risk-based events before they occur. A library of pre-defined physical and integrated security risks can be tied to key indicators such as terminated users, abnormal badge usage or watch listed identities. Aggregating, correlating and processing data from multiple external systems can provide a graphical view of key metrics to enable quick decision-making and to promote awareness and understanding of risks.

Under the umbrella of compliance, software can quickly identify and mitigate concerns and ensure that cardholder access control is driven by policy, that change history is always available and that dormant/orphaned accounts are reliably deactivated. Software can provide centralized enforcement of internal or external regulations. In addition to CFATS, regulatory concerns include the U.S. Maritime Transportation Security Act’s (MTSA) requirement to implement the Transportation Worker Identification Credential (TWIC) program.

CFATS lists a set of broad-based standards to ensure protection of critical chemical facilities but does not specify how the standards are to be achieved. That piece of the puzzle is left up to the facilities themselves, working in conjunction with various hardware and software providers, consultants and integrators. Because of the broad nature of CFATS requirements, achieving them requires a combination of technology and security-related operations and policies. Rules-based software can bridge the gap between technology and operations by integrating adherence to security policies as part of a unified identity management program. Software can automate and enforce global physical security policies and help to ensure both governance and compliance using an organization's existing physical security and IT infrastructure. Unifying hardware solutions with security policies using rules-based software that is custom-configured to a site's specific needs is a cost-efficient and effective route to CFATS compliance.

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