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After 10 Years, CFATS a Cornerstone of America’s Chemical Security

Last month, the Chemical Facility Anti-Terrorism Standards (CFATS) program turned 10 years old. It is now clear that, with every year that goes by, the CFATS program becomes more mature. To a large extent, our success is thanks to not only the work done by the men and women of the Department of Homeland Security (DHS), but also to our industry stakeholders and regulated community, who provide us with continuous feedback on how to better secure  America’s highest-risk chemical facilities. CFATS has become a cornerstone of America’s chemical security culture and the new normal in securing certain chemicals that could be used by terrorists for nefarious purposes. 

Looking back just a year ago, we set the bar quite high from the beginning. After working together for nearly three years across the chemical security community, we rolled out the enhanced tiering methodology and improved CSAT 2.0 tool. The goal was to improve the methodology and ensure it is science-based, as well as reduce the burden on industry by decreasing the amount of time it takes to submit the required paperwork and comply with CFATS. Did you know it only takes an average of 28 minutes to input your information into a blank Top-Screen survey? It takes even less if you have already submitted a survey in CSAT, as you’ll find the form is populated with your previously submitted information and you only need to update it as needed. 

At this time last year, the journey toward reevaluating risk for approximately 27,000 chemical facilities felt enormous. We embarked on the process to notify each facility to resubmit a Top-Screen survey through CSAT 2.0 so we could retier them based on the enhanced methodology. In just one year, the program not only notified all facilities, but also received approximately 23,000 unique facility Top-Screen submissions, and issued close to 22,000 tiering determination letters. Of the roughly 3,500 facilities that are currently assessed as high-risk, 2,271 have approved security plans in place, while the rest are in the works. As we wrap up CFATS’ first decade, we will continue to work on the retiering efforts and compliance inspections. 

Although CFATS’ focus during the past fiscal year has been on implementing the enhanced tiering methodology, our business as usual activities continued in full force. FY17 was very successful in terms of compliance inspections, and DHS met its goals by completing approximately 1,700 facility inspections and 840 compliance assistance visits. 

For the first time in 10 years, DHS held its Chemical Security Summit outside the National Capital Region, in Houston, Texas. The location reflected a strategic choice, given that the petro-chemical industry has a robust foothold in and around Houston. Holding the Summit outside the NCR was also in line with our desire to support the Office of Infrastructure Protection’s focus on enhanced regional services and bring resources closer to those outside Washington D.C.

FY17’s hurricane season also emphasized for us some hard but valuable lessons. It highlighted the importance of maintaining continuous open communication lines with covered chemical facilities especially prior to, during, and after an expected emergency. It also underscored how crucial continuity of operations plans are when disaster hits—and ultimately how important it is for facilities to plan contingencies for all hazards. 

As we leave 2017 behind and enter 2018, we look forward to several things. The National Academies of Sciences published a report on “Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals.” We look forward to reviewing their findings and see how they can help inform the Department of Homeland Security’s approach to this issue. We will continue our focus on the retiering efforts and compliance inspections. And finally, as the program’s existing authorization draws near its conclusion, we look forward to engaging the chemical security community to develop new authorizing legislation. 2018 looks promising, and we look forward to working with all our stakeholders – from industry, labor, and the public sector – to protect America’s highest-risk chemical infrastructure.  

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