Compliance Director Says DHS to Quicken Pace of Site Inspections

Dennis Deziel, acting director of the Department of Homeland Infrastructure Security Compliance Division (ISCD), provided a snapshot on progress the agency has made to date in implementing the Chemical Facilities Anti-Terrorism Standards (CFATS), including its plans to step up site inspections.

He spoke to members of the National Association of Chemical Distributors at the 22nd annual Operations Seminar and Trade Show, held Aug. 18-20 in Austin, Texas.

As of Aug. 15, ISCD had reviewed more than 38,000 Top Screens, which are questionnaires that enable DHS to determine a preliminary risk level (Tier, 1, 2, 3, or 4 with 1 having the highest risk.) The division also had reviewed 6,000 Security Vulnerability Assessments (SVAs), a tool that measures a facility's security efforts and vulnerabilities. SVAs can result in a final tier placement or a determination that the facility is excluded from further regulation. Of the more than 3,500 Site Security Plans that have been submitted, more than 3,000 have been through a quality analysis/quality control review and were scored. These plans must meet Risk-based Performance Standards in line with their tier placement, security issues and other circumstances. Those standards cover more than 15 activities, including:

  • restricting area perimeter,
  • securing site assets,
  • screening and controlling access,
  • personnel surety, and
  • records.

On the ground, chemical inspectors have made more than 250 compliance assistance visits. While the division had conducted 80 preliminary authorization inspections, it was planning to ramp up these visits to 30 to 40 per month. ISCD is planning to fill 268 positions by the end of this year; most of those job openings are in inspection and enforcement, technical analysis, and programs and policy branches.

Since the division began its work until July, it has determined that 226 facilities are in Tier 1, 531 facilities are in Tier 2, 1,132 facilities are in Tier 3, and 2,221 facilities are in Tier 4. Diezel said 887 facilities were awaiting final tier determinations, with only 4 of these having a preliminary Tier 4 assessment.

According to Deziel, the Chemical Security Assessment Tool is the backbone of the CFATS program. It is the secure, Web-based system that facilities access for the 12-step process of determining their level of risk and what they must do to lower it.

As DHS has moved forward, the agency has developed and shared various tools to facilitate regulatory compliance including a help desk, a CFATS tip line for anonymous chemical security reporting, and a Helpful Tips document that is scheduled to be available in September. In addition, staff have conducted hundreds of outreach meetings and calls with site visits to more than 250 regulated sites.

Deziel noted in his presentation that colleges and universities, hospitals, warehouses, semi-conductor manufacturing, chemical repackaging operations, paint and chemical manufacturers, oil and gas operations, and mining industries also may be subject to CFATS, depending on the amount and quantities of chemicals of interest (pdf) that they have or plan to have, regardless of holding time. The types of facilities also may change in the future because the Department of Homeland Security may revise Appendix A, which contains the chemicals of interest list. The list includes toxic, flammable and explosive chemicals.

NACD and its 380 member companies provide products to more than 750,000 end users. They make a delivery every six seconds while maintaining a safety record that is more than twice as good as the safety standards set by the Department of Transportation. NACD members are leaders in health, safety, security, and environmental performance through implementation of Responsible Distribution, established in 1991 as a condition of membership and is a third-party verified management practice.

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