OCS Updates Monthly Statistics – 1-3-22

Yesterday, CISA’s Office of Chemical Security(OCS) updated the statistics on their Chemical Facility Anti-Terrorism Standards (CFATS) Monthly Statistics page. This provides a snapshot look at the activities of the chemical security inspectors (CSI) and the status of the covered facilities at the end of December 2021. At this time, OCS is not including CSI activities in support of the ChemLock program. There was a slight decrease, month-to-month, in CSI activity levels and a net loss in the number of covered facilities in December.

CSI Activities

The table below provides a look at the reported figures for CSI activities over the last four months.

As is expected in December due to the holidays, there was a general decrease in the number of reported activities conducted by the CSI. The total of 189 reported activities is significantly higher, though, than the 129 reported in December 2020. Much of the variation in activity level is driven by variation in facility requests for assistance and when facilities last had a compliance inspection.

For all practical purposes, there were no activities in support of the ChemLock program last month. OCS announced during last month’s Chemical Security Seminars that the first CSI visits in support of the new voluntary chemical security program would not start until this month. As I noted above, OCS does not currently intend to include ChemLock support in this reporting, so it will be interesting to see if we can indirectly see an impact.

Facility Status

The table below provides a look at the facility status information provided by OCS over the last four months.

There was a net loss of nine covered facilities in December even though there was small increase in the number of facilities with approved site security plans. It is hard to parse the changes in numbers in this report. For example, the lack of change in the number of facilities in ‘Tiered’ status (Top Screen submitted and classified as a covered facility, but the facility site security plan has not yet been authorized) could mean that no new facilities moved into the program and none of last month’s ‘Tiered’ facilities had their SSP authorized. Or all of last months facilities could have had their SSPs authorized and 57 new facilities could have entered the program. I suspect that it is somewhere in between, but closer to the former.

From a chemical security perspective, a decline in the number of covered facilities is actually a good thing. The CFATS program is built on the premise that the possession of certain DHS chemicals of interest above a threshold quantity make (with some other risk assessment concerns that are hidden in the OCS black box) place a facility at risk of a terrorist attack. Significant reduction or elimination of those risks at a facility (necessary for exit from the program) reduces the risk for the communities around those facilities and the country as a whole.

But that risk is not eliminated (except where facilities close) just reduced. With the advent of the ChemLock program, facilities leaving the CFATS program have a mechanism to continue to receive support from CISA in protecting their facilities.