In May of last year, DHS (Department of Homeland Security) started sending out final tier ranking letters to facilities falling under CFATS (Chemical Facility Anti-terrorism Standards).  The letters notify facilities of a final tier ranking between 1 and 4, tier 1 facilities posing the highest risk and tier 4 facilities presenting the least amount of high risk.  Letters are being sent out in waves to the more than 7,000 facilities affected and DHS now says that they all should receive a final teiring letter by the end of this coming summer.  

So what are the tiers and how are they determined?  DHS does not provide specific information on how tiers are assigned but it does list some criteria.  The tiers result from the fact that CFATS is risk-based.  DHS recognized that the facilities falling under the mandates vary considerably. They can include a large petrochemical and chemical processing plant producing and processing thousands of gallons of chemicals a day, to a campus facility storing chemicals for research, to a manufacturer of electronic products using chemicals in the manufacturing process.  All of these fallunder the CFATS mandate, but they are all very different, present different degrees of risk and require different security solutions and plans.

So, DHS knew that there was not a one size fits all solutionfor facilities using, storing, producing and processing chemicals and it came up with a system to rank them according to risk.  That ranking comes from a review of the initial "top screen" and "SVA" (Security Vulnerability Assessment) submitted by facilities to DHS via the CSAT, (Chemical Security Assessment Tool.)

While not getting into specifics, DHS does list threecriteria for assigning risk. 

· Consequences - the potential impact of an attack on a facility

·  Vulnerabilities - the likelihood of an attack being successful

·  Threat - the likelihood of an attack taking place at a facility

DHS has also said that it will take into consideration the presence of chemicals with a "critical impact on governance mission and the economy." This would include chemicals that are crucial for the needs of the community and its citizens and if destroyed in an attack, would put the surrounding community at risk.

CFATS allows facilities to put together realistic security and safety plans and reserve resources and expenditures for those with the highest overall risk.

Ryan Loughin is Director of Petrochemical & Energy Solutions for the Advanced Integration division of ADT- www.adtbusiness.com/petrochem. He provides security education to CFATS and MTSA-affected companies and is a member of the National Petrochemical and Refiners Association (NPRA), Society of Chemical Manufacturers and Associates (SOCMA), Energy Security Council (ESC) and American Society for Industrial Security (ASIS). Loughin has also completed multiple levels of CVI Authorized User training (Chemical- Terrorism Vulnerability Information) which was authored by the U.S. Department of Homeland Security.

 

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