As the industry looks ahead to 2012, the Chemical Facility Anti-Terrorism Standards (CFATS) will continue to have a significant impact, especially as more sites undergo Authorization Inspections.
Don Keen, Acting Eastern District Commander, Infrastructure Security Compliance Division, DHS, joined me at the 4th Annual Homeland Security Regulatory Briefing, held in Houston, TX on November 1, 2011 to provide an update on CFATS. The event included more than 130 attendees and panelists from the Department of Homeland Security (DHS), the United States Coast Guard and many other guests from the regulatory community. Highlights from the presentations include:
- Though several different CFATS authorization bills were proposed in the 112th Congress, the industry should not expect to see any permanent or long-term CFATS legislation pass during this session. Most recently, Congress once again temporarily extended CFATS through a Continuing Appropriations Act until November 18, 2011 and it is likely that the program will be extended temporarily again into 2012 through ad hoc legislation.
- Numerous sites have made material modifications, with nearly 1,250 facilities eliminating their Chemicals of Interest (COIs) completely and approximately 600 other sites reducing the quantity of COIs on-site to levels below the screening threshold.
- Sites submitting a Site Security Plan (SSP) should be detailed in their response, in order to "paint a picture" for those at DHS headquarters who will be reviewing it - yet will likely never see the site firsthand.
- Department of Homeland Security has conducted nine Authorization Inspections (AIs), but no facility has yet to receive a Letter of Approval. DHS continues to conduct AIs and will give each site at least 30 days notice before the AI. DHS will also notify the facility regarding which site personnel should be available for the AI. For each AI, facilities should expect six to eight DHS inspectors to be present and to spend approximately five days on-site. Companies with more than one site are advised to share learnings across sites as they are inspected.
- Finally, sites are encouraged to reach out to local chemical security inspectors in order to establish a rapport.
- DHS hired additional staff to review SSPs, which should hopefully streamline the process.
By Guest Blogger, Steve Roberts, Chemical Security Consulting & Training Services, Inc.
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