What to Expect for the CFATS Inspection Process
Just a few notes from the NPRA Security Conference in Houston last week. I listened to a presentation by Richard Cary, a Chemical Security Inspector for the Inspections & Enforcement Branch within the Infrastructure Security Compliance Division (ISCD) in the National Protection and Programs Directorate at the U.S. Department of Homeland Security (DHS). He is also one of three district commanders.
As an inspector and area commander Cary has great info on the inspection process and what to expect.
One of the first things to know is that DHS will visit your company's headquarters prior to facility inspections. This will help companies with multiple facilities falling under CFATS. The three area commanders will coordinate headquarter visits for companies with sites in more than one region or jurisdiction.
The facility inspection starts when the lead DHS inspector reaches out to the facility. DHS is required to begin the inspection process in a timely manner but inspectors should give you at least 24-hour notice or longer. In most cases, you should expect at least four inspectors to visit your facility depending on the complexity of the facility and DHS will provide you with a list all the inspectors attending. At the same time, DHS will expect a list of everyone attending from your facility and his or her areas of responsibility.
Plan for a five-day inspection with eight hours or more a day and one evening or nighttime inspection to check lighting and camera visuals. DHS inspectors will start with a tentative agenda and then specify for the site. They will want to know safety regulations and requirements and anything special they should be looking for or need to know.
The goal is to start the inspection process at 9 a.m. on a Monday or Tuesday and to begin with a safety briefing and orientation. DHS inspectors will be asking for a lot of info based on your SSP. They will also have a long list of records requests that can include:
• Lighting Survey
• Maintenance and Testing Logs on equipment
• SOP for Security Function
• Visitor Log
• Training Log
• Vehicle Entry Log
In instances where a facility is using third party monitoring of alarm or video services, DHS would expect to have the info and coordination provided at the site ahead of time.
You should also have individuals from the following departments to talk with DHS. Not all at once, but individually:
DHS inspectors want to get different perspectives, so as they tour the facility they will be stopping and talking with other people. The goal is to get as much information as they can, so that they can put together a complete and accurate report. They want the inspection to go as smoothly as possible with no surprises for the facility or DHS.
At the end of the facility inspection DHS inspectors will provide an "Out-brief" for the site. A copy of the inspectors' report will not be provided to the facility. The report is for internal DHS use only, but the inspectors will share the contents with the facility verbally. The official correspondence resulting from the inspection will be a DHS letter to the facility.
Steven Partridge is Regional Manager - West for ADT Advanced Integration. He is a member of the American Chemical Council (ACC) and the Society for Chemical Manufacturers Affiliates (SOCMA) and the Chemical Industry Council of California (CICC).
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