2012 Chemical Sector Security Summit: ISCD Regulatory Update

At the 2012 Chemical Sector Security Summit, David Wulf, Director, Infrastructure Security Compliance Division (ISCD), Department of Homeland Security (DHS) provided an ISCD regulatory update.

Mr. Wulf began by reviewing the current status of the Chemical Facility Anti-Terrorism Standards (CFATS) program, noting that in the 5 years since the inception of the program, ISCD has developed a comprehensive picture of the nation’s chemical infrastructure and identified the “highest-risk” chemical facilities. To date, ISCD has received over 43,000 Top-Screens, 7,300 Security Vulnerability Assessments, conducted over 3,000 outreach visits, and preliminarily approved 63 Site Security Plans (SSPs)

ISCD has also now developed a final SSP review process to ensure quicker and more efficient SSP reviews and approvals. Among other things, Mr. Wulf anticipates that local chemical inspectors will be more involved in the review process (e.g., as deficiencies are identified, local chemical inspectors will work directly with facilities to remedy issues or collect additional information). ISCD also intends to host industry working groups in the coming months to identify ways to enhance and streamline the SSP itself.  

With its newly-developed Chemical Inspector Authorization Inspection (AI) Training course nearly complete, ISCD recommenced AIs in July and is scheduled to complete approximately 20 by the end of September. It expects to schedule additional AIs later in 2012 and throughout 2013.

We’ll continue to monitor the CFATS program closely, so be sure to visit the blog regularly for updates.

You can learn more about CFATS inspections by downloading the white paper: Surviving the CFATS Site Security Plan -Tips for Inspection & Resubmission.

Ryan Loughin is Director of Petro, Chemical & Energy Solutions for Tyco Integrated Security. He and his team have led many petrochemical security projects in North America, South America, Europe, Africa and Asia. Loughin has more than 14 years of experience in petrochemical and energy security and provides security education and services to CFATS (Chemical-Facility Anti-Terrorism Standards) and MTSA (Maritime Transportation Security Act) -affected companies. Loughin is a member of the National Petrochemical and Refiners Association (NPRA), Society of Chemical Manufacturers and Affiliates (SOCMA), American Chemistry Council (ACC), Energy Security Council (ESC) and American Society for Industrial Security (ASIS). Loughin has worked with hundreds of MTSA and CFATS affected sites and has also provided guidance on many ACC Responsible Care Security Code projects.

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