Chemical Security Inspector Reduction in Force

Part 3

Yesterday I published a guest post by a CISA Chemical Security Inspector about the role of the CSI in the Chemical Facility Anti-Terrorism Standards (CFATS) program and their pending abolition in the current restructuring of the Cybersecurity and Infrastructure Security Agency. I thought that that letter was important enough that it should stand on its own before I added my two cents worth.

First, I want to clear up a mistake on my part in the introduction of yesterday’s post. I stated that the post was written by CSI that had “recently received their reduction in force notification.” What they had received from CISA was an advanced notice about the reorganization of CISA that has been described elsewhere. The actual RIF notices have not yet been sent out. What they were told was that the CSI were no longer required. About the only thing that can stop that is action by Congress, which is, unfortunately, unlikely to happen.

CSI and CFATS

The letter opens with a description of the importance of the CFATS program and the role of the CSI within that program. What is overlooked in that description is that fact that many of the chemical facilities that were visited by the authors (I understand that the letter was a group effort) and their compatriots had little or no experience in matters of physical and cybersecurity. The CSI were valuable conduits of information, not only of the CFATS Risk Based Performance Standards (the core of the CFATS security program), but what types of controls and devices were successfully being used by other facilities in similar situations.

It cannot be overstated that the CSI were the face of CFATS programs for the covered chemical facilities. That should be kept in mind when we look at the outpouring of industry support for restarting the CFATS program. When facility managers think about the CFATS program they think about the Chemical Security Inspectors that helped their facilities successfully deal with the requirements of that program.

CSI as Liaison

There is an interesting discussion about the role CSI played as liaison between chemical facilities and law enforcement. While covered facilities are required to report incidents to appropriate law enforcement agencies, that reporting is not always easy. The reason being that many things that chemical facilities are encouraged to report (frequent drive byes, photo taking, questions being asked of employees) fail to reach the level of concern of many police departments. The presence of (or contact by) a federal security inspector helps those departments realize the importance of the issues being reported.

CSI Post CFATS

To my way of thinking, the most important part of the letter comes in the discussion about what the CSI have been doing since the expiration of the CFATS program. To understand this discussion one first needs to understand the CSI did not report to Office of Chemical Security, they belonged to the Integrated Operations Division. That division (as I have described here and here) is responsible for the operation of CISA’s regional offices. Once there were no longer requirements for CSI to visit covered facilities, the Regional Offices used them to augment their Protective Security Advisors and Cybersecurity Advisors. This allowed them to visit and assist smaller chemical facilities that were not the focus of the CFATS program.

The important thing here is that the CFATS program was only focused on a very small portion of the very broadly defined chemical sector. Defined by the possession of one or more 300+ chemical that could be used as, or used to make, chemical weapons by terrorists, at arbitrarily set minimum volumes. There were more than 40,000 companies that met the reporting requirements for the program over the years and only a little more than 3,000 were covered facilities when the program terminated in July of 2023. That shows how many more chemical facilities could have used the advice of these CSI.

Moving Forward

In the face of the mass layoffs at so many federal agencies, many would ask why I would take up the case of these eighty or so CSI that are most probably facing their own layoffs. The simple answer is that I have been advocating for them and their compatriots for the last 16 years or so and I am not going to stop now. More importantly, I have a solid understanding of what CISA and DHS are going to lose if these CSI are going to be let go. This is a valuable resource that CISA will eventually deeply regret losing.